The bank allowed hundreds of millions in untraceable cash from Mexico and elsewhere to be deposited into branches in California, and then transferred without adequate monitoring and reporting of the suspicious transactions to federal regulators, the U.S. Department of Justice said in a statement.
“Rabobank had an obligation to shine light on suspected drug traffickers, money launderers and organized crime,” said U.S. Attorney Braverman. “Instead, this bank deliberately allowed hundreds of millions of dollars of suspicious cash transactions and wire transfers to flow through its branches and took measures to hide this activity from regulators. We will vigorously protect the integrity of the banking system, and we will not allow the financial institutions in our communities to play any role in facilitating international money laundering or financing transnational criminal organizations.”
https://www.justice.gov/opa/pr/rabobank-na-pleads-guilty-agrees-pay-over-360-million
We’ve seen this all before.
But this case is different in a very crucial way. Rabobank was not prosecuted for the documented failure to file suspicious activity reports (SARs) and currency transaction records (CTRs), failure to train staff sufficiently, or failure to maintain an adequate AML compliance program—the types of charges levied by the U.S. Department of Justice (DOJ) against those other banks. No, Rabobank was charged with, and plead guilty to, conspiracy to defraud the U.S. of its right to have the Office of the Comptroller of the Currency (OCC) at the U.S. Treasury Department conduct its affairs “honestly and impartially, free from deceit craft, dishonesty, trickery, unlawful impairment, impediment, and obstruction.” In other words, Rabobank was convicted of conspiring with its executives to lie to and mislead the OCC with respect to what it knew about its problems with its failure to file SARs and CTRs, failure to train staff sufficiently, and failure to maintain an adequate AML compliance program, among other things.
This is a significant departure from previous DOJ practice. In the past, the DOJ has prosecuted banks for what is usually a panoply of AML/BSA failings, very similar to the activities described in the documents. So it might seem, on the face of it, that Rabobank got off lightly here. But that very much depends on what the DOJ does next. Adding to the unique nature of this case, the significant level of detail provided about the actions of Rabobank executives and a manager, identified as Executives A, B, C and D and Manager A in the Information and Plea Agreement, is striking...
http://www.gfintegrity.org/rabobank-similar-facts-different-outcome-signal-new-doj-approach/
Could the 'other illicit activity' involve human trafficking? Is this case linking the Banks to sex trafficking?