Assessment of Banko de Chile’s Anti-Money Laundering Compliance Program

Introduction

The Financial Crimes Enforcement Network (FinCEN) has conducted an assessment of Banko de Chile’s anti-money laundering compliance program, highlighting several key issues that led to a failure to identify and report suspicious transactions involving a prominent politically exposed person and their family members.

Key Points

• FinCEN assesses Banko de Chile for failing to maintain an effective anti-money laundering (AML) compliance program.
• The bank’s failure to identify, review, or evaluate large dollar value transactions involving the individual and their family members led to a breach of AML regulations.

Background

Banko de Chile operates branches in New York and Miami, which are subject to strict anti-money laundering regulations. Despite this, the bank failed to adhere to these regulations, resulting in significant non-compliance issues.

Key Facts

• Banko de Chile has branches in high-risk areas such as New York and Miami.
• The bank failed to identify, review, or evaluate large dollar value transactions involving a prominent politically exposed person and their family members.

Violations of the Bank Secrecy Act (BSA)

Banko de Chile’s failure to maintain an effective AML compliance program led to several significant violations of the BSA and its implementing regulations. These include:

Violation Details

• Failure to timely report suspicious activity.
• Inadequate maintenance of an AML compliance program.
• Failure to identify, review, or evaluate large dollar value transactions.

Civil Money Penalty

FinCEN has determined that a civil money penalty is due for Banko de Chile’s violations of the BSA and its implementing regulations. The penalty amount is $3 million.

Details of the Penalty

• FinCEN determines a civil money penalty of $3 million.
• The bank consents to the assessment and agrees to pay the penalty within five business days.

Consent to Assessment

Banko de Chile has consented to the assessment and agreed to pay the civil money penalty of $3 million. This payment will be made within five business days of the assessment.

Release of Liability

• By consenting to the assessment, Banko de Chile releases any civil liability related to its AML compliance program.

Conclusion

This document highlights the importance of maintaining effective anti-money laundering compliance programs by financial institutions, particularly those with branches in high-risk areas such as New York and Miami.