In a concurrent action, the Financial Crimes Enforcement Network (FinCEN) has assessed a civil money penalty of $15 million for violations of the BSA. The payment of $15 million to the United States Department of the Treasury will satisfy both FDIC and FinCEN assessments.

The New York State Department of Financial Services has also imposed a civil money penalty of $10 million against Shinhan Bank America for violations of state AML laws and regulations.

The FDIC has determined that the bank failed to implement an adequate AML program over an extended period of time. The inadequate BSA/AML internal controls resulted in the bank being unable to adequately identify and manage illicit financial activity risk to the institution.

Shinhan Bank America has been ordered to pay the civil money penalty. The bank has not yet commented on the matter.

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