
The Bank did not detect or investigate suspicious activities and did not file SARs as required. In particular, the Bank failed to: (a) refer specific inquiries from law enforcement to the area that investigated suspicious activities to determine whether SAR filings were appropriate; (b) file accurate Currency Transaction Reports and SARs, in part, based upon inaccurate or incomplete information maintained about Bank customers; (c) file timely SARs for any of the transactions listed in paragraph (7) of this Article; and (d) investigate suspicious activities occurring in accounts related to the countries of Saudi Arabia and Equatorial Guinea. (7) The Bank did not adequately monitor for suspicious cash, wire, or monetary instrument transactions. In particular, the Bank failed to identify or to monitor potentially suspicious activity pertaining to: (a) tens of millions of dollars in cash withdrawals from accounts related to the Saudi Arabian embassy; - 6 - (b) dozens of sequentially-numbered international drafts that totaled millions of dollars, that were drawn from accounts related to officials of Saudi Arabia, and that were returned to the Bank; (c) dozens of sequentially-numbered cashier’s checks that were drawn from accounts related to officials of Saudi Arabia made payable to the account holder; (d) millions of dollars deposited into a private investment company owned by an official of the country of Equatorial Guinea; (e) hundreds of thousands of dollars transferred from an account of the country of Equatorial Guinea to the personal account of a government official of the country; and (f) over a million dollars transferred from an account of the country of Equatorial Guinea to a private investment company owned by the Bank’s relationship manager.