The Banksters

0x3…6f4

ERC721

U.S. Bank willfully violated the BSA’s program and reporting requirements from 2011 to 2015. 4 As described below, U.S. Bank failed to: (a) establish and implement an adequate antimoney laundering (AML) program from 2011 to 2014; (b) report suspicious activity from 2011 to 2014, and; (c) adequately report currency transactions from 2014 to 2015. Rather than maintaining effective, risk-based policies, as required by the BSA, U.S. Bank devoted an inadequate amount of resources to its AML program from 2011 to 2014. First, the Bank capped the number of alerts its automated transaction monitoring system would generate for investigation. Testing indicated that these caps caused the Bank to fail to investigate and report large numbers of suspicious transactions. Nonetheless, instead of removing the alert caps, the Bank terminated the testing that demonstrated the caps’ deficiencies.

Name

1157

Owner

0x91ED1310bc8E36e5a90A996387E43e79fBbec88d

ID#1157

Rarity

LO:63%