All in Regulatory Update

FinCEN Announces $140 Million Penalty Against USAA FSB for BSA Violations

Adam Witmer
Regulatory Update, BSA

On March 17, 2022, FinCEN announced that it has assessed a $140 million civil money penalty against USAA Federal Savings Bank (USAA FSB) for willful violations of the Bank Secrecy Act (BSA) and its implementing regulations. This is after FinCEN conducted a civil enforcement investigation and determined that grounds exist to impose a Civil Money Penalty against USAA FSB for violations of the BSA. According to the FinCEN’s press release, USAA FSB admitted that it willfully failed to implement and maintain an anti‑money laundering (AML) program that met the minimum requirements of the BSA from at least January 2016 through April 2021.

CFPB Focuses on Unfair Discrimination

Adam Witmer
Regulatory Update, UDAAP

On March 16, 2022, the CFPB announced changes to its supervisory operations to better protect families and communities from illegal discrimination, including in situations where fair lending laws may not apply. According to the CFPB, the Bureau will closely examine discriminatory practices that violates the rules against unfair practices. Specifically, the CFPB will focus on financial institutions’ decision-making in advertising, pricing, and other areas to ensure that companies are appropriately testing for and eliminating illegal discrimination.

Treasury Issues Sanctions for Enabling Putin’s War Against Ukraine

Adam Witmer
Regulatory Update

On March 11, 2022, the OFAC issued a new round of sanctions targeting Russian and Kremlin elites, oligarchs, and Russia’s political and national security leaders who have supported Russian President Vladimir Putin’s brutal and illegal invasion of Ukraine. The OFAC designated regime elites and business executives who are associates and facilitators of the Russian regime, including three immediate family members of President Putin’s spokesperson, Dmitriy Sergeevich Peskov; Russian tycoon and Kremlin insider Viktor Vekselberg; and the Management Board of the sanctioned VTB Bank. Additionally, the OFAC designated 12 members of the Russian State Duma, including Vyacheslav Victorovich Volodin, who is also a permanent member of Russia’s Security Council.

FATF Updates List of Deficient Countries

Adam Witmer
BSA, Regulatory Update

On March 10, 2022, FinCEN issued a press release to inform U.S. financial institutions that the Financial Action Task Force (FATF), an intergovernmental body that establishes international standards to combat money laundering, counter the financing of terrorism, and combat weapons of mass destruction proliferation financing (AML/CFT/CPF), has issued public statements updating its lists of jurisdictions with strategic AML/CFT/CPF deficiencies following its plenary meeting this month. U.S. financial institutions should consider the FATF’s stance toward these jurisdictions when reviewing their obligations and risk-based policies, procedures, and practices.

OCC Acting Comptroller Discusses Climate Risk, Diversity and Inclusion

Adam Witmer
Regulatory Update

On March 7, 2022, Acting Comptroller of the Currency Michael J. Hsu spoke at the at the Institute of International Bankers Annual Washington Conference where he discussed climate-related financial risk and the importance of promoting diversity and inclusion in the banking industry. The IIB, according to Hsu, has a long history of bringing together senior government officials and industry leaders to address policy and business issues of importance to the international banking community in the United States.

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