Civil penalty of $450,000 assessed against former Chief Operational Risk Officer of financial institution

The Financial Crimes Enforcement Network has assessed a civil money penalty against the former Chief Operational Risk Officer of US Bank National Association, a full-service financial institution headquartered in Cincinnati, for failing to prevent violations of the Bank Secrecy Act during his tenure at the bank.  

FinCEN determined that Michael LaFontaine, who served as Deputy Risk Officer and Chief Compliance Officer prior to becoming Chief Operational Risk Officer, had responsibility for overseeing US Bank’s compliance program, and therefore shares in the bank’s responsibility for failing to implement and maintain an effective anti-money laundering program and file suspicious activity reports as required by the BSA.  According to FinCEN, prior to and during LaFontaine’s leadership, US Bank allotted inadequate staffing resources to its compliance function, and improperly capped the number of alerts allowed to be generated by the automated monitoring system.  And despite having been warned by two separate bank anti-money laundering officers and by the Office of the Comptroller of the Currency that imposing numerical caps on the monitoring program could result in a potential enforcement action, US Bank and LaFontaine did not properly address these concerns.  

LaFontaine consented to the assessment of a civil money penalty of $450,000, and has agreed that for the six-year period beginning in June 2014 when he left the bank, until February 26, 2020, he has not performed a compliance management function for any financial institution.  LaFontaine admitted to participating in US Bank’s violation of the Bank Secrecy Act, and conceded that his conduct and that of the bank demonstrated recklessness or reckless disregard. 

In February 2018, US Bank paid a civil money penalty of $185 million for willfully violating the BSA’s compliance program and suspicious activity reporting requirements.

FinCEN press release | Assessment of Civil Money Penalty

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