When it comes to monitoring anti-money laundering (AML) compliance, the Office of the Comptroller of the Currency (OCC) can strike fear into the hearts of U.S. financial institutions–and does so on a regular basis with massive fines and sanctions. As it turns out, the OCC wields considerable power with foreign banks as well, and not just those in countries where U.S. citizens like to offshore assets.

Take Rabobank, a well-known Dutch financial institution, and a global leader in underwriting food and agricultural businesses. It’s one of the 30 largest financial institutions in the world, with 682 locations outside of its home country, including several branches in California. In 2013, it received a $1 billion fine from the OCC for manipulating interest rates; Chief Executive Piet Moerland resigned immediately in the wake of that scandal, and three former traders were criminally charged.

You’d think that a $1 billion fine would be a big wake-up call that the OCC is closely watching the bank’s operations… but apparently not. Just last month, the OCC ordered Rabobank to fix problems with its AML programs, requiring the bank to appoint a compliance committee and to conduct an assessment of locations and products that pose significant risk to the bank. Although no new fines were levied, the message is clear: AML programs are continuing to be at the top of the OCC’s priority list for close scrutiny.

by Richard Paxton

Want to learn more? Alacer’s AML experts will be attending the 19^th Annual AML & Financial Crimes Conference, being held March 16-19 at the Westin Diplomat in Hollywood, FL. Send an email to me at Richard@alacergroup.com to arrange a chat.