FinCEN’s $390 Million Case Against Capital One – And What It Means For AML Enforcement
Seetha Ramachandran and Hena Vora, 29 March 2021
As the financial services industry prepares for expanded criminal and civil enforcement under the Bank Secrecy Act (“BSA”) with the passage of the Anti-Money Laundering Act of 2020, FinCEN’s recent case against Capital One shows how FinCEN’s approach to AML enforcement is evolving.
On January 15, 2021, FinCEN assessed a $390 million civil money penalties against Capital One for violations of the BSA related to Capital One’s Check Cashing Group (the “CCG”). CCG is a business unit under Capital One’s commercial bank through which Capital One provides banking services including processing checks and providing customers with armored car cash shipments. In issuing its decision, FinCEN determined that, between 2008 and 2014, Capital One’s CCG failed to report millions of dollars in suspicious transactions. Specifically, FinCEN found that Capital One: Continue reading “Article: FinCEN’s $390 Million Case Against Capital One – And What It Means For AML Enforcement”

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