Enforcement action issued against Atlantic Community Bankers Bank
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Banking
Tuesday, October 13, 2020
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The Federal Reserve Board recently issued an enforcement action against the Atlantic Community Bankers Bank (ACBB) of Camp Hill, Pa., citing deficiencies in the bank’s compliance with anti-money laundering regulations.
The board and ACBB agreed to a written statement that outlines what the bank must do to be considered compliant.
The agreement states that within 60 days, ACBB must:
- Submit a written plan that strengthens board oversight of the bank’s compliance with Bank Secrecy Act/Anti-Money Laundering (BSA/AML) requirements and Office of Foreign Assets Control (OFAC) regulations.
- Submit an enhanced written BSA/AML compliance program, subject to the Federal Reserve’s approval.
- Submit a written revised customer due diligence program, subject to the Federal Reserve’s approval.
- Submit a written enhanced program to “reasonably ensure the identification and timely, accurate, and complete reporting by the bank of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious reporting laws and regulations.” Program is also subject to approval by the Federal Reserve.
- Engage with an independent third party (approved by the Federal Reserve) to validate the effectiveness of the bank’s transaction monitoring system and prepare a written report regarding that system.
- Submit a written plan for “independent testing of the bank’s compliance with all applicable BSA/AML requirements.”
- Submit a plan to enhance compliance with OFAC regulations, subject to approval.
- Submit a revised internal audit program, also subject to approval.
Within 10 days of finding an independent third party to validate and report on the bank’s transaction monitoring system, the bank must submit an engagement letter to the Federal Reserve for approval. ACBB will also be required to submit a written progress report within 30 days of the end of each calendar quarter. Approved plans and programs are to be adopted within 10 days of approval.
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