Regulatory Alerts2015-12-30 | 2015-12Added
Assessment of Civil Money Penalty in the Matter of B.A.K. Precious Metals, Inc.
FinCEN assessed a $200,000 civil money penalty against B.A.K. Precious Metals, Inc., its sole owner Bogos Karaoglanyan, and compliance officer Arman Karaoglanyan for willfully violating Bank Secrecy Act requirements. The violations included failing to implement an effective anti-money laundering program, specifically neglecting risk assessments, customer due diligence, training, and independent testing. The parties consented to the penalty and agreed to undertake specific remedial actions, including engaging an external independent reviewer for testing in 2016, 2018, and 2020, and submitting annual compliance reports through 2020.
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