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almost all of this cash flowed through accounts that Tucker maintained during the Bank

almost all of this cash flowed through accounts that Tucker maintained during the Bank

An OCC examiner assigned to your Bank repeatedly warned USB officials, like the AMLO, for the impropriety of handling the Bank’s monitoring programs in line with the measurements of its staff along with other resources. Comprehending that the OCC would find USB’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 Bank’s methods, plus in order to guard himself along with his manager from undesirable effects. Certainly, the AMLO described USB’s AML system to a different senior supervisor as a work to utilize “smoke and mirrors” to “pull the wool throughout the eyes” associated with the OCC.

USB additionally neglected to monitor Western Union (“WU”) 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 Bank’s deal monitoring systems. Even if Bank workers flagged particular non-customer deals increasing AML-related issues, the transactions went uninvestigated.