On February 27th, the Financial Crime Enforcement Network (FinCEN) assessed a $1.5 milliion civil monetary penalty (CMP) against First National Community Bank (FNCB) of Dunmore, Pennsylvania for violations of the Bank Secrecy Act (BSA) by not filing Suspicious Activity Reports (SARs) for transactions related to a judicial corruption scheme. The activity went unreported for a period of five years. Why? Probably because one of the two judges involved, a Michael Conahan, was on the bank's board of directors.
And what should have tipped FNCB off? From the FinCEN press release:
The unreported suspicious
transactions that flowed through Conahan’s and other FNCB accounts displayed red flags that
should have alerted FNCB to potential illicit activity and caused it to file suspicious activity
reports. These red flags included (1) a 2007 law enforcement subpoena for information related
to Conahan and other individuals and entities – although the Bank responded to the subpoena, it
did not conduct any further analysis or risk rate the accounts as required; (2) activity occurring as
early as 2005 involving many large, round-dollar transactions often occurring on a single day;
and (3) an abnormal volume of activity compared to account balances.