$1 Million Penalty Assessed Against Pamrapo Savings For Bank Secrecy Act Violations

The Financial Crimes Enforcement Network (“FinCEN”) today announced the assessment of a civil money penalty of $1 million against Pamrapo Savings Bank, S.L.A., of Bayonne, N.J. for violating requirements under the Bank Secrecy Act (“BSA”). FinCEN’s announcement contained some particularly harsh words, including these: “Pamrapo’s lack of internal controls combined with unqualified BSA compliance personnel, relatively non-existent training and deficient independent testing resulted in a wholly ineffective BSA compliance program which, in turn, resulted in the failure to file a substantial number of currency transaction and suspicious activity reports in an accurate and timely manner.” 

The bank, without admitting or denying the allegations, consented to payment of the civil money penalty.
 
FinCEN found that between January 1, 2005 and April 21, 2009, the bank “flagrantly and repeatedly disregarded the most basic BSA requirements which resulted in an ineffective Anti-Money Laundering program and significant reporting failures.”
 
In addition, according to FinCEN, “bank management did not heed a bank regulatory recommendation that a third party evaluate the bank’s BSA program. Bank management misled regulators by indicating this recommendation was given strong consideration at the highest levels of the bank but decided against taking action on it, when in fact, this recommendation was not considered at all.”
 
Further, FinCEN declared, “the lack of understanding of basic BSA requirements resulted in the failure to identify, evaluate and risk rate dozens of higher risk accounts to mitigate potential BSA/AML risks.”