An OCC examiner assigned towards the Bank repeatedly warned USB officials, like the AMLO, of this impropriety of handling the BankвЂ™s monitoring programs in line with the size of its staff along with other resources. Understanding that the OCC would find USBвЂ™s resource-driven limits that are alert be poor, Bank officials, such as the CCO, intentionally concealed these techniques through the OCC. As an example, a Bank employee intentionally excluded recommendations to site restrictions through the mins of a interior Bank meeting for fear that the OCC would disapprove for the BankвЂ™s methods, plus in purchase to guard himself along with his manager from unfavorable effects. Certainly, the AMLO described USBвЂ™s AML system to a different senior supervisor as an work to make use of вЂњsmoke and mirrorsвЂќ to вЂњpull the wool within the eyesвЂќ associated with the OCC.
USB additionally did not monitor Western Union (вЂњWUвЂќ) deals involving non-customers of this Bank that occurred at Bank branches. The Bank processed WU transactions involving non-customers despite the fact that they might never be susceptible to the BankвЂ™s deal monitoring systems. Even if Bank workers flagged particular non-customer transactions increasing AML-related issues, the transactions went uninvestigated. Continuer la lecture de the majority of this cash flowed through accounts that Tucker maintained in the Bank