An OCC examiner assigned to your Bank repeatedly warned USB officials, like the AMLO, for the impropriety of handling the BankвЂ™s monitoring programs in line with the measurements of its staff along with other resources. Comprehending that the OCC would find USBвЂ™s resource-driven alert restrictions to be incorrect, Bank officials, like the CCO, deliberately concealed these methods through the OCC. As an example, a Bank employee intentionally excluded recommendations to site restrictions through the mins of an Bank that is internal meeting fear that the OCC would disapprove of this BankвЂ™s methods, plus in order to guard himself along with his manager from undesirable effects. Certainly, the AMLO described USBвЂ™s AML system to a different senior supervisor as a work to utilize вЂњsmoke and mirrorsвЂќ to вЂњpull the wool throughout the eyesвЂќ associated with the OCC.
USB additionally neglected to monitor Western Union (вЂњWUвЂќ) deals involving non-customers regarding the Bank that occurred at Bank branches. The Bank processed WU transactions involving non-customers and even though they might never be at the mercy of the BankвЂ™s deal monitoring systems. Even if Bank workers flagged particular non-customer deals increasing AML-related issues, the transactions went uninvestigated.