Personal Liability Exposure for Bank Executives and Compliance Officers
On 4 March 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its assessment of a civil monetary penalty totaling USD 450’000 against Michael LaFontaine, a former Chief Operational Risk Officer at U.S. Bank National Association (U.S. Bank). FinCEN determined that Mr. LaFontaine among other things, failed to prevent violations of the Bank Secrecy Act (BSA) and failed to ensure U.S. Bank’s compliance division was appropriately staffed to meet its compliance obligations.
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