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Archive for FMBE

The ongoing saga of FinCEN and FBME – Let Round 3 Begin.

FinCEN re-issued its order March 25, 2016 [Download FBME_Final Rule March 25 2016] declaring that FBME is a bank of primary money laundering concern, setting the state for the court showdown between the agency and the bank FBME (it’s a dispute that I have been following for a couple years because of the uneven treatment that was applied to this little, unheard of bank versus “banks too big to fail”.On the one side, FinCEN finds that FBME is a great scourge to the US Financial System (“primary money laundering concern”) and the only remedy for such egregious behavior is to shut the bank down (i.e. cancel its correspondent accounting relationships with the US, and thus US dollars).  FinCEN states that it gave FBME every opportunity to reform itself and that FBME simply refuses to do so.  FinCEN points to lack of employee education and training, lack of client diligence and monitoring, as well as transactions.  FinCEN also restates all of its former charges.   Read more