
In the 2015 Consent Order, the Comptroller found that the Bank violated 12 U.S.C. § 1818(s) and its implementing regulation, 12 C.F.R. § 21.21 (BSA Compliance Program), and 12 C.F.R. § 21.11 (Suspicious Activity Report Filings). Specifically, the 2015 Consent Order addressed the following conduct: (a) The Bank failed to adopt and implement a compliance program that adequately covered the required BSA/AML program elements due to an inadequate system of internal controls and ineffective independent testing, and the Bank failed to file all necessary Suspicious Activity Reports (“SARs”) related to suspicious customer activity;