Zions, without admitting or denying the facts or allegations, consents to an $8 million civil money penalty, which was assessed with the Office of the Comptroller of the Currency and this was satisfied by a payment of $8 million to the U.S. Department of the Treasury.
FinCEN determined that Zions violated the requirements of the BSA as it failed to establish and implement an effective anti-money laundering (AML) programme in respect to its foreign correspondent banking relationships with casas de cambio, banks, casas de bolsa and foreign corporate customers, and also failed to file 'timely' suspicious activity reports."Both traditional and emerging products and services, such as remote deposit capture, must be accompanied by appropriate compliance measures to manage the risk for abuse," said FinCEN Director James H. Freis, Jr.
"While the violations were to some extent historic, lapses or breakdowns in compliance can nonetheless result in civil monetary penalties, as warranted. Particularly with new product development, financial institutions must stay abreast of emerging risks and informational sources such as government advisories, publications, examination manuals and other relevant materials to mitigate such risks."
(Well, so long as they did it 'prayerfully' that would have been OK, then? Sometimes these kind of things make one wonder...)