The Office of the Comptroller of the Currency's recent Consent Order against Community Federal Savings Bank is a useful case study in how compliance programs fall behind. The bank's payment processing business scaled significantly after 2020. The risk controls didn't. Monitoring thresholds went uncalibrated. An automated alert system closed cases it shouldn't have. By the time examiners arrived, the gap was hard to defend. Our latest article breaks down what happened and what it means for banks navigating growth in payments and cross-border activity. Link in the comments.
The Office of the Comptroller of the Currency just issued a Consent Order against CFSB, a New York bank, for BSA/AML violations. 💭The bank didn't ignore compliance. It just never updated it as the business grew. Since 2020, payment processing volume scaled significantly. Monitoring thresholds didn't. An automated alert system was quietly closing cases it shouldn't have. CDD couldn't keep up with cross-border risk. By the time examiners looked, the gap was too wide to explain away. This is a useful gut-check for any bank or a regulated institution that's added a new product line or payments relationship in the last few years.