Alert February 22, 2011

FinCEN and OCC Assess Concurrent $8 Million Penalty Against Zions for Deficiencies in its AML Program

Zions First National Bank (“Zions”), headquartered in Salt Lake City, Utah, consented to an $8 million penalty assessed concurrently by FinCEN and the OCC.  Zions consented to the penalty assessments without admitting or denying culpability.  FinCEN and the OCC found that Zions violated Bank Secrecy Act requirements because Zions’ anti-money laundering compliance program, and the manner in which the program was implemented, were deficient with respect to correspondent relationships with foreign exchange bureaus and with respect to their remote deposit capture product.