An OCC examiner assigned towards the Bank repeatedly warned USB officials, like the AMLO, associated with 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 alert restrictions to be poor, Bank officials, like the CCO, intentionally concealed these techniques from the OCC. For instance, a Bank employee intentionally excluded references to site limits through the moments of an interior Bank meeting for fear that the OCC would disapprove regarding the BankвЂ™s methods online payday loans Georgia, as well as in purchase to guard himself along with his manager from undesirable effects. Indeed, the AMLO described USBвЂ™s AML system to a different senior supervisor as a work to make use of вЂњsmoke and mirrorsвЂќ to вЂњpull the wool on the eyesвЂќ of this OCC.
USB additionally neglected to monitor Western Union (вЂњWUвЂќ) deals involving non-customers regarding the Bank that occurred at Bank branches. The Bank processed WU transactions involving non-customers despite the fact that they’d never be susceptible to the BankвЂ™s deal monitoring systems. Even though Bank workers flagged certain non-customer deals increasing AML-related issues, the deals went uninvestigated.