06/01/2026
$2 billion in transactions. Five employees. One AML program that never kept up. 💰
FinCEN assessed a $300,000 civil money penalty against a Florida credit union after it processed over $2 billion in a single year for 56 high-risk MSBs across Central America, the Middle East, and Mexico.
That volume made up 90% of the institution's annual revenue. The AML program was still built for a small community credit union.
Here is what FinCEN found:
1️⃣ The AML program never reflected the institution's actual risk profile.
2️⃣ No adequate monitoring existed for high-risk international MSB activity at that volume.
3️⃣ The credit union failed to comply with Section 314(a) of the USA PATRIOT Act.
4️⃣ BSA recordkeeping and reporting obligations were not met.
🔍 The third-party vendor introduced the accounts. The BSA obligations stayed with the credit union. We broke down what happened and what it means for your program.
Link here 👉 https://truthtechnologies.com/north-dade-fincen-penalty/