CommunityBank of Texas, N.A.
Texas
On December 16, 2021, FinCEN issued a consent order against CommunityBank of Texas for willful violations of the Bank Secrecy Act. The bank maintained inadequate AML staffing, with overburdened analysts reviewing approximately 100 alerts daily, leading to systemic failures in transaction monitoring and customer due diligence. CBOT failed to file at least 17 Suspicious Activity Reports (SARs) during the 2015–2019 period. FinCEN assessed a total civil money penalty of $8 million, with a $1 million credit applied for a prior penalty imposed by the OCC for related deficiencies. While this action does not directly involve a fintech partnership, the AML weaknesses identified—inadequate staffing, poor transaction monitoring, and CDD failures—mirror the risk areas regulators have highlighted in BaaS and bank-fintech arrangements.
Verified from source: On December 16, 2021, FinCEN entered into a Consent Order with CommunityBank of Texas, N.A., assessing an $8 million penalty for willful failure to effectively implement its AML program between 2015 and 2019, with CBOT receiving a $1 million credit for a separate OCC penalty.
- Reinforces regulatory expectation that banks must adequately staff and resource AML compliance programs regardless of business model
- SAR filing failures and transaction monitoring deficiencies are areas of heightened scrutiny for sponsor banks facilitating fintech programs
- Dual-agency enforcement (FinCEN + OCC) signals coordinated supervisory attention to BSA/AML violations
- Banks entering BaaS partnerships should ensure transaction monitoring capacity scales with volume to avoid similar enforcement outcomes