Question
TQ6.1: What are the four minimum requirements for an anti-money laundering program according to FinCEN? TQ6.2: What information did Mingo fail to include in its
TQ6.1: What are the four minimum requirements for an anti-money laundering program according to FinCEN? TQ6.2: What information did Mingo fail to include in its Customer Identification Program, and what risks did this failure entail for the anti-money laundering system? TQ6.3: What information did U.S. Bank fail to include in its Customer Identification Program, and what risks did this entail for the anti-money laundering system? TQ6.4: In what ways did senior management at U.S. Bank impair the bank's ability to detect and report suspect transactions? TQ6.5: In what ways were senior bank management at Mingo complicit in failures to comply with BSA regulations?
In the Matter of U.S. Bank National Association In the Matter of Bank of Mingo, Williamson, West Virginia Pete Schroeder, U.S. Bancorp to Pay $613 million for Money-Laundering Violations, Reuters, Feb, 15, 2018 West Virginia's Bank of Mingo Pays $4.5 Million for BSA/AML Compliance Program Deficiencies, Showing that Small and Midsize Institutions Also Face Enforcement Scrutiny
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