FinCEN levies $140M civil penalty against USAA Federal Savings Bank

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WASHINGTON — The Financial Crimes Enforcement Network has assessed a $140 million civil money penalty against USAA Federal Savings Bank for willful violations of the Bank Secrecy Act and its implementing regulations.

Specifically, USAA FSB admitted it willfully failed to implement and maintain an anti‑money laundering program that met the minimum requirements of the Bank Secrecy Act from at least January 2016 through April 2021. The bank’s case alert and investigation system was “chronically deficient,” investigators asserted.

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.

“As its customer base and revenue grew in recent years, USAA FSB willfully failed to ensure that its compliance program kept pace, resulting in millions of dollars in suspicious transactions flowing through the U.S. financial system without appropriate reporting,” said FinCEN’s Acting Director Himamauli Das. USAA FSB, a federally chartered savings bank headquartered in San Antonio, Texas, “also received ample notice and opportunity to remediate its inadequate anti-money laundering program, but repeatedly failed to do so.”

The Office of the Comptroller of the Currency 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.

FinCEN is a bureau within the U.S. Department of the Treasury, and its Office of Enforcement is responsible for investigating serious violations of the Bank Secrecy Act.