Agricultural Bank of China Limited


Industry: Banking & Finance
Underlying Misconduct: Money Laundering
Matter Type: State Attorney General
Relevant Jurisdiction(s): New York
Penalties: Civil Penalties
Fine Amount: $215,000,000
Reporting Agencies: NY Department of Financial Services
Resolution Form: Consent Agreement
Agreement Date: November 4, 2016
Monitor Reference Term: Independent Monitor
Monitor Identity: Unknown
Monitorship Term: 1 Year
Monitor Selection Process:

Selected by the Department in its sole discretion. Applicants were solicited on the Department's website.

Time to Propose Monitors: N/A
Time to Engage Monitor: 60 days
Time to First Report: 120 days
Reporting Frequency:
Monitor Required Qualifications:

None specified; however, would require Anti-Money Laundering, Bank Security Act and OFAC experience and knowledge.

Summary of Monitor's Scope:

Though called an Independent Monitor, the scope was primarily a one time review of aspects of the Host Organization's AML/BSA and OFAC compliance programs.

Summary of Monitor's Activities:

Identify all of the business lines, activities, and products to ensure that they are appropriately risk-rated and included in the Host Organization's BSA/AML compliance program, policies, and procedures. Conduct a comprehensive assessment of the BSA/AML compliance program, policies, and procedures. Conduct a review of the NY Branch's US dollar clearing transaction activity from May 1, 2014 through October 31, 2015, to determine whether transactions inconsistent with or in violation of the OFAC regulations and suspicious activity reporting regulations and the New York law.

Monitor's Restrictions:

None noted.

Documents Uploaded: Agricultural-Bank-of-China-NYDFS-Consent-Order-4Nov2016.pdf