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COPYRIGHT 2005 Access Intelligence, LLC.
After a hiatus over the summer, two consent orders dealing with Bank Secrecy Act (BSA) violations have emerged. One is from the Office of the Comptroller of the Currency (OCC) against KeyBank, and the other is from the Federal Reserve Bank of New York and the New York Banking Department against Deutsche Bank Trust Co. Americas. Both were cited for inadequate--or, in the case of KeyBank, apparently missing--BSA compliance mechanisms. No fines were issued in either case.
The KeyBank order is extensive. Among its directives, the bank must:
* Create a compliance committee drawn from board members;
* Draw up a set of BSA compliance policies, including compliance with the Office...
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