Consent Order Imposing Civil Money Penalty Against Shinhan Bank America

UNITED STATES OF AMERICA
FINANCIAL CRIMES ENFORCEMENT NETWORK
DEPARTMENT OF THE TREASURY
IN THE MATTER OF: )
) Number 2023-03
Shinhan Bank America )
New York, NY )
CONSENT ORDER IMPOSING CIVIL MONEY PENALTY
The Financial Crimes Enforcement Network (FinCEN) conducted a civil enforcement investigation and determined that grounds exist to impose a Civil Money Penalty against Shinhan Bank America (SHBA or the Bank) for violations of the Bank Secrecy Act (BSA) and its implementing regulations.1 SHBA admits to the Statement of Facts and Violations set forth below and consents to the issuance of this Consent Order.
I. JURISDICTION
Overall authority for enforcement and compliance with the BSA lies with the Director of FinCEN, and the Director may impose civil penalties for violations of the BSA and its implementing regulations.2 At all times relevant to this Consent Order, SHBA was a “bank” and a “domestic financial institution” as defined by the BSA and its implementing regulations.3 As such, SHBA was required to comply with applicable FinCEN regulations.
II. STATEMENT OF FACTS
The conduct described below took place from on or about April 1, 2016, through on or about March 29, 2021 (Relevant Time Period), unless otherwise indicated.