February 22, 2019

Bank of Tokyo-Mitsubishi settles cease and desist proceedings by OCC

The Office of  the Comptroller of the Currency of the US Department of the Treasury has issued a cease and desist order against the primary entity and two branch banks of the Bank of Tokyo-Mitsubishi UFJ, Ltd. (the Banks). The Comptroller found that the Banks violated  12 C.F.R. §§ 21.21, 21.11 and 31 C.F.R. § 1010.610 by failing to adopt and implement a compliance program that covered the required Bank Secrecy Act and anti-money laundering elements; by failing to file Suspicious Activity Reports in a timely manner; and by failing to implement adequate due diligence programs for correspondent accounts of foreign institutions.  Without admitting or denying the Comptroller’s findings, the Banks consented to the provisions of the order, including:  to develop a written action plan describing the corrective actions necessary for the Banks to comply with the Order, defining timelines for completion, and identifying the Bank personnel responsible for implementation of the corrective actions.  The Order also requires the Banks to maintain a permanent, qualified and experienced BSA officer,  to implement an effective BSA/AML Risk Assessment process, to perform adequate customer due diligence, to monitor and report on suspicious activities, and to implement an effective BSA/AML audit program.

OCC News release | Consent order (February 2019) | Consent order (November 2017)