Business Crimes Hotline

Bank Pays $36.1 Million for Failure to Maintain Effective Anti-Money Laundering Program

On Sept. 17, 2007, UnionBanCal Corporation's, subsidiary Union Bank of California, N.A. consented to the filing of an information and entered into a deferred-prosecution agreement for a violation of the Bank Secrecy Act, for failing to maintain an effective anti-money laundering program. The company's resolution includes a $26.1 million forfeiture settlement, required implementation of anti-money laundering measures, as well as $10 million in concurrent civil penalties by both the Financial Crimes Enforcement Network, and the Office of the Comptroller of the Currency; resulting in a grand total of $36.1 million. The charges relate to activity in Union Bank of California accounts held by certain Mexican currency exchange houses. Specifically, through undercover operations and investigation, authorities identified monies in these accounts as proceeds resulting from the export of cocaine from Colombia to Mexico, with ultimate intended destinations in the U.S. and Europe. According to authorities, these suspicious transactions were not detected, identified or reported, as required by the Act, because of deficiencies in the company's anti-money laundering program. United States v. Union Bank of California, N.A., 3:07cr02566, (S.D. Cal. Sept. 17, 2007).