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Mega International Commercial Bank


Industry: Banking & Finance
Underlying Misconduct: Money Laundering
Matter Type: State Attorney General
Relevant Jurisdiction(s): New York
Penalties: Civil Penalties
Fine Amount: $180,000,000
Reporting Agencies: NY Department of Financial Services
Resolution Form: Consent Order
Agreement Date: August 19, 2016
Monitor Reference Term: Independent Monitor
Monitor Identity: Unknown
Monitorship Term:
Monitor Selection Process:

Not specified in Order. NYDFS generally solicits applications publicly and chooses the Monitor. Should also be noted that no specific time frame was contained in the Order - end of Order is subject to Reporting Agency's apparent discretion.

Time to Propose Monitors: N/A
Time to Engage Monitor: 30 days
Time to First Report: 60 days
Reporting Frequency:
Monitor Required Qualifications:

Not specified in Order. May be more apparent in application.

Summary of Monitor's Scope:

Conduct a comprehensive review of the effectiveness of a Branch's program for compliance with BSA/AML requirements, laws and regulations and prepare a written report of findings, conclustions and recommendations.

Summary of Monitor's Activities:

1) Identify all of the Branch's business lines, activities, and products to ensure they are appropriately risk-rated and included in the BSA/AML compliance program, policies, and procedures; 2) conduct a comprehensive assessment of the Branch's BSA/AML compliance program, policies, and procedures; 3) complete the Compliance Review within 60 days after approval; 4) provide to the Department a copy of the Compliance Report at the same time that the report is provided to the Host Organization and Branch; 5) commit that any and all interim reports, drafts, workpapers, or other supporting materials associated with the Compliance Review will be made available to the Department; 6) conduct a review of dollar clearing transaction activity from 1/1/12 through 12/31/14 to determine whether transactions consistent with or in violation of the OFAC regulations, or suspicious activity involving high risk customers or transactions or possible money laundering at, by, or through the Branch were properly identified and reported in accordance with OFAC regulations and suspicious activity reporting regulations and the New York law and prepare a written report detailing findings.

Monitor's Restrictions:

None specified.

Documents Uploaded: Mega-Intl-Commercial-Bank-NYDFS-CA-19Aug2016.pdf