The US Office of the Comptroller of the Currency has imposed a swingeing penalty on Holland's Rabobank for long-standing, but now remedied, deficiencies in its anti-money-laundering efforts.

The bank's failure to run a good anti-money-laundering/Bank Secrecy Act regime (or 'programme') dates back to 2012. Its systems at that time, and for some time after, were not able to monitor, investigate and report incidents of customers acting suspiciously, particularly in transactions that traversed borders and/or involved large sums. On top of that, the bank's processes were not sufficiently 'customer duly diligent' (CDD, a term invented by the Basel Committee for Banking Supervision) or 'enhanced duly diligent' (EDD, a term invented around the same time by the USA PATRIOT Act 2001) and its compliance staff were not good enough at investigating questionable activity related to subpoenas and requests that police submitted to them pursuant to s314(a) USA PATRIOT Act. The bank's auditing efforts were weak and its compliance offices (US regulators have now taken to making pronouncements about how many compliance people should be on the payroll) were understaffed and badly trained. These were grievous errors, compounded by the fact that the bank hid documents from the OCC that it had asked to see.
 
The OCC has now countermanded (or 'terminated') the consent order (also known as a 'cease and desist' order) because the bank "has implemented all of the corrective actions...and has achieved compliance with the requirements set forth in that order." There are, however, no pending criminal charges for bank executives in sight.

One can speculate that the fine would have been even higher if Rabobank had failed to obey the five-year-old court order. Last month Citibank had to pay a civil penalty of US$70 million to the US Treasury, having failed to comply with an OCC court-backed consent order of 2012 regarding failures to make suspicious activity reports. No criminal charges were laid simultaneously against staff. Citigroup amalgamated its AML efforts into a single centralised function on 1st March 2016; according to Reuters, other big banks with remediation problems in that year split their AML compliance and operations functions apart from one another to allow the operations people to concentrate on improving efficiency while saving money.

Rabobank, whose website bears a portrait (pictured) of a man about to be shot at by drones, straddles the market between wealth management and commercial banking. After a successful test launch last summer, it has opened Rabo & Co, a platform which brings entrepreneurs who want to borrow money and wealthy bank clients who want to invest together. This is an echo of Rabobank's original purpose which, according to director Rien Nagel, was to link wealthy farmers up with farmers who required money. Some time ago, Nagel told the press about the new venture: "The money will now go directly from the high-net-worth individual to the business in need of funds. If the platform is successful, we intend to open it to institutional investors as well."