The most common problems for the banks that have been hit with the multi-million dollar fines included management review and board oversight. Board and upper management buy-in is key for top-down compliance. "The important thing is you have to have a process and follow that process and make sure your staff is doing that as well," she explained.
Other problems that were similar between Riggs Bank and ABN AMRO and some of the others who have been publicly fined are inadequate internal audit and noncompliance with the Office of Foreign Assets Control.
While no credit unions have as yet been hit with the mega-fines these institutions have, there are other risks. First, Bahin noted, a $15 million credit union back in February has been asked to go back and file any Suspicious Activity Reports it had missed over the last seven years, which comes at an enormous cost and takes away from the actual business of the institution. There are also additional reputational and regulatory risks as well.