FinCEN has determined that CONA violated certain of its BSA obligations for a particular business unit, namely, its Check Cashing Group (CCG), from in or about 2008 through in or about 2014. As described below in the Statement of Facts, CONA willfully failed to establish and maintain an effective anti-money laundering (AML) program to guard against money laundering within the CCG. Further, CONA willfully4
failed to accurately and timely file suspicious activity reports (SARs) on suspicious transactions associated with the CCG. Last, CONA negligently failed to timely file currency transaction reports (CTRs) for the CCG. CONA’s violations of its BSA obligations resulted in the failure to accurately and timely report millions of dollars in suspicious transactions, including proceeds connected to organized crime, tax evasion, fraud, and other financial crimes laundered through the Bank into the U.S. financial system.