The US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has determined a US$1.5 million penalty against the First National Community Bank of Dunmore, Pennsylvania (FNCB) for wilfully violating the Bank Secrecy Act (BSA).
The bank admitted that it failed to file suspicious activity reports on transactions involving illicit proceeds from a judicial corruption scheme – spanning over five years – for which Mark Ciavarella and Michael Conahan, both former Pennsylvania judges, were ultimately convicted.
Ciavarella and Conahan misused their positions as judges to profit from, among other things, sending thousands of juveniles to detention facilities in which they had a financial interest.
Conahan was on FNCB’s board of directors and controlled accounts at the bank through which he processed the proceeds of his illegal activity.
Despite several red flags indicating suspicious activity, FNCB did not file a single suspicious activity report related to these accounts until after Conahan’s first guilty plea in 2009.
“The criminal case affected the lives of thousands of children and parents,” said FinCEN director, Jennifer Shasky Calvery.
“Banks have a duty to spot suspicious activity and to report it. Law enforcement relies on this valuable information. FNCB’s failure to file timely suspicious activity reports may have deprived law enforcement of information valuable for tracking millions of dollars in related corrupt funds,” she said.
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