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Expert Analysis

Lessons From Rabobank's Anti-Money Laundering Failures

By Michael Gertzman, Jessica Carey, Roberto Gonzalez and Jeffrey Newton ( February 20, 2018, 12:24 PM EST) -- On Feb. 7, 2018, the U. S. Department of Justice[1] and the Office of the Comptroller of the Currency[2] announced the imposition of $368,701,259 in penalties on Rabobank NA, the California-based subsidiary of the Dutch financial services company. Notably, in addition to agreeing to a substantial forfeiture and civil money penalty, Rabobank agreed to plead guilty to one count of conspiracy to obstruct the OCC's attempts to identify deficiencies in Rabobank's Bank Secrecy Act/anti-money laundering compliance program. . . .

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