" Under the authority of the Bank Secrecy Act and the regulations issued pursuant to that Act, the Financial Crimes Enforcement Network has determined that a civil money penalty is due for violations of the Bank Secrecy Act, as described in this ASSESSMENT.
Based on the seriousness of the violations at issue in this matter, and the financial resources available to Sigue, the Financial Crimes Enforcement Network has determined that the appropriate penalty in this matter is $12,000,000.
- Violations of the Requirement to Implement an Anti-Money Laundering Program
The Financial Crimes Enforcement Network has determined that Sigue violated the requirement to establish and implement an effective anti-money laundering program. Since July 24, 2002, the Bank Secrecy Act and it's implementing regulations have required money services businesses to establish and implement anti-money laundering programs. An effective program is one that is reasonably designed to prevent the money services business from being used to facilitate money laundering and the financing of terrorist activities.4 The regulation requires money services businesses to implement written anti-money laundering programs that, at a minimum" (1) incorporate policies, procedures and internal controls reasonably designed to ensure ongoing compliance; (2) designate a person to assure day-to-day compliance; (3) provide training of appropriate personnel; and (4) provide for independent review to monitor and maintain an adequate program.5 The failure ot establish and implement an effective anti-money laundering program disabled management at Sigue from implementing measures to respond to continued patterns of suspicious activity, wityh repeated common characteristics, at certain agent locations."