WASHINGTON — The Financial Crimes Enforcement Network has announced that it assessed a $2 million fine on Foster Bank in Chicago for Bank Secrecy Act violations.

According to the order, Foster did not implement an adequate BSA compliance program; the institution failed to include an anti-money laundering program with internal controls, independent testing and other measures to detect and report potential money laundering, terrorist financing and other suspicious activity.

"This failure led, in turn, to the Bank's failure to timely file suspicious activity reports, including at least one report concerning a money transmitter business responsible for wiring millions of dollars from primarily cash deposits to beneficiaries in Pakistan, India, and the United Arab Emirates," it read. "The Bank also improperly exempted two money services business customers from the currency transaction reporting requirements of the Bank Secrecy Act. As a result of these improper exemptions, the Bank filed at least 674 delinquent currency transaction reports for transactions conducted by the two customers. Finally, the Bank failed to adhere to the prohibition against structuring currency transactions to evade the reporting or recordkeeping requirements of the Bank Secrecy Act."

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The FinCEN order continued, "The failures of Foster to comply with the Bank Secrecy Act were significant. The Federal Deposit Insurance Corporation and the State of Illinois Office of Banks and Real Estate imposed a Cease and Desist Order on Foster on March 14, 2003, to address Foster's Bank Secrecy Act deficiencies. The Order was terminated on January 7, 2005."

FinCEN held off on imposing the fine to avoid prejudicing other government proceedings with the initiation of a civil penalty action.

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