An OCC examiner assigned into the Bank repeatedly warned USB officials, like the AMLO, associated with impropriety of handling the BankвЂ™s monitoring programs in line with the size of its staff as well as other resources. Comprehending that the OCC would find USBвЂ™s resource-driven alert restrictions to be incorrect, Bank officials, such as the CCO, intentionally concealed these methods through the OCC. As an example, a Bank employee deliberately excluded recommendations to site limits through the moments of a interior Bank conference for fear that the OCC would disapprove associated with BankвЂ™s techniques, as well as in purchase to guard himself and their manager from undesirable effects. Certainly, the AMLO described USBвЂ™s AML system to some other senior supervisor as an work to make use of вЂњsmoke and mirrorsвЂќ to вЂњpull the wool throughout the eyesвЂќ associated with the OCC.
USB additionally neglected to monitor Western Union (вЂњWUвЂќ) deals involving non-customers of this Bank that occurred at Bank branches. The Bank processed WU transactions involving non-customers and even though they’d never be at the mercy of the BankвЂ™s transaction systems that are monitoring. Even if Bank workers flagged particular transactions that are non-customer AML-related issues, the deals went uninvestigated. It had been perhaps maybe not until July 1, 2014, that the lender applied a policy that is new prohibited WU transactions by non-customers. (mais…)