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WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) assessed a $15 million civil money penalty against Shinhan Bank America (SHBA) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations.
“SHBA willfully disregarded its obligations under the BSA to maintain an effective anti-money laundering (AML) program and to identify and report suspicious transactions to FinCEN, despite being informed of its deficiencies as far back as 2015,” said FinCEN’s Director Andrea Gacki. “Today’s action should serve as a reminder to banks of all sizes that AML program deficiencies must be promptly and effectively addressed, and that FinCEN takes seriously repeated failures to remediate violations of the BSA.”
SHBA admitted to willfully violating the BSA from April 2016 through March 2021, by failing to implement and maintain an effective AML program that was reasonably designed to guard against money laundering and failing to timely report several hundred transactions to FinCEN involving suspicious financial activity by its customers processed by, at, or through the bank. As a result, tens of millions of dollars in suspicious transactions were not reported to FinCEN in a timely manner, including transactions connected to tax evasion, public corruption, money laundering, and other financial crimes.
FinCEN appreciates the close collaboration with its partners at the Federal Deposit Insurance Corporation (FDIC) on this matter and thanks the New York State Department of Financial Services (NYDFS). The FDIC assessed a civil penalty of $5 million for related violations and FinCEN will credit that penalty. The NYDFS also assessed a civil penalty of $10 million today for AML-related violations.
FinCEN’s Office of Enforcement is responsible for investigating serious violations of the BSA. For additional information regarding the facts and circumstances associated with this enforcement action, including the specific BSA violations and their underlying causes, please see the Consent Order between FinCEN and SHBA.