Bayonne, N.J.-based Pamrapo Savings Bank S.L.A.'s lack of internal controls, unqualified BSA compliance staff, deficient independent testing and lack of training resulted in a "wholly ineffective BSA compliance program," FinCEN said in announcing the fine Thursday.
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Between January 2005 and April 2009, the bank "flagrantly and repeatedly disregarded the most basic BSA requirements," the bureau said. Without admitting or denying the allegations, the bank consented to payment of the civil penalty, according to FinCEN.
On March 29, Pamrapo Savings Bank, a wholly owned subsidiary of Pamrapo Bancorp Inc., pleaded guilty in U.S. District Court to conspiracy to violate the BSA and agreed to forfeit $5 million to the U.S.
According to federal prosecutors, Pamrapo Savings Bank conspired to conceal its customers' illegal or suspicious activities by failing to file currency transaction reports and suspicious activity reports and by failing to maintain an adequate anti-money laundering program. Executives at the bank admitted that the bank willfully violated BSA to avoid expenses associated with compliance, officials said.
The Office of Thrift Supervision assessed a $5 million civil penalty against the bank, which was deemed satisfied by the $5 million forfeiture. The bank faces no less than one year but not more than five years probation.