U.S. Fed Taiwanese Bank AML Fine

On Jan. 17, Fed fined Mega Int. Commercial bank $29mn for AML.

  • Taipei, Taiwan, based bank breached US AML regulations, and was fined $29mn.
  • Taiwan FSC asked bank to fully explain to Fed, its efforts to enhance compliance.

Findings

  • Followed Fed review of bank's branches in New York, Chicago, and Silicon Valley.
  • US bank operations did not maintain effective program to comply with BSA, AML.

AML Requirements

  • Fed required that firm improve its anti-money laundering oversight and controls.
  • Established targets for corporate governance and board, management oversight.
  • BSA/AML compliance program, a system of internal control, independent testing.
  • Management of branch AML compliance program, by qualified compliance officer.
  • Effective training for branch and affiliate personnel that perform AML compliance.
  • Suspicious activity monitoring and reporting, data collected across business lines.

Due Diligence Requirement

  • Program for conducting customer due diligence information for account holders.
  • Documentation to verify their identity, source of wealth, and business activities.
  • Records needed to understand normal and expected transactions for a customer.
  • Method to assign risk rating, for type of customer/products/services, geography.