Rabobank, National Association settles compliance program matters

OCC consent order of California-based Rabobank subsidiary terminated

Rabobank, National Association (RNA), a California-based subsidiary of Coöperatieve Rabobank U.A. (Rabobank), has entered into agreements with the U.S. Department of Justice and the Office of the Comptroller of the Currency (OCC). The agreements conclude previously reported investigations involving Bank Secrecy Act / Anti-Money Laundering (BSA/AML) compliance program deficiencies and related conduct by certain former employees before 2014. Recognizing the material improvements the bank has made to its BSA/AML compliance program, the OCC has terminated the Consent Order issued in December 2013.

RNA has agreed to pay approximately EUR 298 million (USD 369 million) in forfeiture and civil money penalties and fines. It has also agreed to plead guilty to one charge of conspiring to obstruct a regulatory examination. Under the plea agreement’s terms with the Department of Justice, no further action will be taken against RNA with regard to its BSA/AML compliance program and related conduct. RNA has been under investigation by the U.S. Department of Justice, the OCC and the Financial Crimes Enforcement Network (FinCEN). Given the overlapping nature of the investigations and the bank’s remediation, no additional penalties or measures will be sought by FinCEN, which has also concluded its examination. The settlement amount is in line with the provision that was announced on January 2, 2018 and will be accounted for in the full year results of 2017.
Wiebe Draijer, Chairman of the Rabobank Managing Board, stated: “The findings at our subsidiary RNA relate to events that took place before 2014. The violations that took place are serious, regrettable and unacceptable. Rabobank is fully committed to conducting business with the highest levels of integrity, which includes strict compliance with all applicable laws, regulations, and standards in each of the markets and jurisdictions in which it operates. Rabobank and RNA cooperated fully with all authorities, who specifically acknowledged the bank’s cooperation. RNA, with the full support and backing of Rabobank, has made very strong efforts to strengthen its internal controls and risk management functions, which is also recognized by the authorities.” 

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