The New Your Branch of Sumitomo Mitsu Bank received a reprimand note and an order to improve governance, management awareness and some other items of their AML program.
In the written order, the bank was requested to create an action plan to address
- the lack of knowledge, awareness and understanding of management regarding AML and sanctions related obligations,
- the poor suspicion reporting system,
- the lack of awareness of management regarding due diligence, and to ensure that the compliance function if appropriately staffed.
The order included the need to ensure that the Chief Compliance Officer is “given full autonomy, independence, and responsibility” and “meaningful decision-making authority”.