The penalty, which is to be equally split between Florida and the federal government, was imposed for:

• Failure to monitor accounts for suspicious transactions.
• Failure to implement internal controls of systems to manage risk in more than 200 internally-identified high-risk accounts.
• Failure to timely file SARs involving more than $1bn of suspicious transactions of a telecom firm over a 21-month period.
• Violation of the terms of a 2004 Cease & Desist Order issued against the bank by federal regulators.

The bank, according to the reports, failed to investigate three of its major money service business clients, who withdrew $ 615m in currency over 18 months. Regulators counted 40 MSBs and six foreign correspondent banks amongst its clients.

One report alleges that SARS for a foreign currency exchange client, totalling $ 226, were filed 2 1/2 years late. One regulator estimated total suspicious transactions at $ 1.6 bn.

A bank spokesman stated that these violations occurred more than two years ago, but no reason has been disclosed for the total and complete breakdown in compliance.