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US v Rabobank NA, SD CA 18CR00614 – Does it pose questions every BSA Officer needs to ask?

On February 7, 2018, Rabobank NA pleaded guilty to a charge of conspiracy to defraud the United States and corruptly obstruct an OCC examination. On May 18th the judge sentenced Rabobank to two years’ probation and the maximum fine of $500,000. This is on top of the previous $368.7 million forfeiture.

There is an interesting passage from the original criminal information. Paragraph 17 provides as follows:

“During certain periods in 2011, the M&I [Monitoring & Investigations] Unit had only two people to handle investigations and only three analysts to monitor and manage thousands of monthly alerts. In other words, during those particular periods, three people were tasked with reviewing approximately 2,300 alerts per month and two people were tasked with conducting more than 100 investigations per month, including approximately 75 customers per month for whom SAR determinations had to be made.”

So the Government appears to be critical that there were only 3 people to clear 2,300 alerts per month … that’s about 733 per person per month, or about 35 per day … and that there were only 2 people to clear 100 investigations per month … that’s just over two cases per day.

The questions every BSA Officer has to ask are these: how many alerts and cases are my folks clearing every day, how does that compare to what the Rabobank analysts/investigators were clearing, and do I have to do something different in my shop as a result?