March 6, 2015 - FinCEN’s Notice

On March 6, 2015, the US Treasury Financial Crimes Enforcement Network (FinCEN) published a notice of finding that designated BPA as a foreign financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act. FinCEN also published an order that prohibited U.S. financial institutions from opening or maintaining accounts and processing transactions involving BPA.

FinCEN did not inform BPA of the accusations against the bank and did not allow BPA to respond prior to the publication of the notice. The bank was, as a result, “killed off” immediately without warning.