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nearly all of this cash flowed through accounts that Tucker maintained in the Bank

nearly all of this cash flowed through accounts that Tucker maintained in the Bank

An OCC examiner assigned towards the Bank repeatedly warned USB officials, like the AMLO, associated with impropriety of handling the Bank’s monitoring programs in line with the size of its staff along with other resources. Understanding that the OCC would find USB’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 Bank’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 USB’s AML system to a different senior supervisor as a work to make use of “smoke and mirrors” to “pull the wool on the eyes” of this OCC.

USB additionally neglected to monitor Western Union (“WU”) 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 Bank’s deal monitoring systems. Even though Bank workers flagged certain non-customer deals increasing AML-related issues, the deals went uninvestigated.