Federal Reserve reprimands and sent order to Japanese Bank

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”.



Jaime Prieto

Mr. Jaime Prieto is a lawyer experienced in Financial Crime, Anti-Money Laundering and Counter Terrorism Financing having extensive professional experience in both public and private sectors. Mr. Prieto has been a Head of Compliance in the European Union, the Americas and the Caribbean for banks, trust companies, asset managers, Big Four audit and advisory firms, RegTechs, government agencies and other types of financial professionals. In addition to his experience, he has been legal and educational chair in several compliance and sectorial organisations and performed as a teacher and speaker for a number of organisations and in several local and international forums. Furthermore, Mr. Prieto is an experienced Money Laundering Reporting Officer anda Data Protection officer with additional experience in risk management.

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