FinCEN announces penalties against USAA

Last week, the Financial Crimes Enforcement Network (FinCEN) announced it completed an investigation, which led to a consent order and a $140 million civil money penalty against USAA Federal Savings Bank (USAA) for violations of the Bank Secrecy Act (BSA) and its implementing regulations. This enforcement action can serve as an example of growing pains and the importance of updating the BSA/AML compliance program as membership and product types expand.

In the consent order, FinCEN explained that USAA had grown substantially in the years 2016 to 2021, yet failed to update its BSA/AML compliance program to match the size and risks associated with the increased bank activities. Specifically, FinCEN describes a list of updates USAA agreed to make in 2018 after its examiners found it to have a deficient compliance program. These improvements were to include:

  • Expand internal controls and testing
  • Establish a compliance committee


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