FinCEN and the OCC have issued enforcement orders against USAA Federal Savings Bank, Austin, Texas, for willful violations of the Bank Secrecy Act and its implementing regulations. USAA FSB admitted that it willfully failed to implement and maintain an anti‑money laundering (AML) program that met the minimum requirements of the BSA from at least January 2016 through April 2021. USAA FSB also admitted that it willfully failed to accurately and timely report thousands of suspicious transactions to FinCEN involving suspicious financial activity by its customers, including customers using personal accounts for apparent criminal activity.
The Office of the Comptroller of the Currency (OCC) assessed a civil penalty of $60 million for related violations. As many of the facts and circumstances underlying the OCC’s civil penalty also form the basis of FinCEN’s Consent Order, FinCEN agreed to credit the $60 million civil penalty imposed by the OCC. Taken together, USAA FSB will pay a total of $140 million to the U.S. Treasury for its violations, with $80 million representing FinCEN’s penalty and $60 million representing the OCC’s penalty.
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