FinCEN and the Office of the Comptroller of the Currency have imposed concurrent civil penalties of $15m against the New York Branch of United Bank for Africa, for its failure to implement an effective AML programme, notwithstanding prior Cease & Desist orders, and civil money penalties. The FinCEN Assessment of Civil Money Penalty recited the bank's history of AML deficiencies, and the regulator's many attempts to motivate it into building an operational anti-money laundering programme. The large penalty may signal that American patience with UBA has come to an end. Will the bank "death penalty," or loss of its charter, be the next, and final, sanction imposed? See below for URLs of the agency orders.

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