- 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.
- 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.
- 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.