Federal Reserve Board Issues Enforcement Action Against Lineage Financial Network and Announces Termination of Enforcement Actions with National Bank of Pakistan and National Bank of Pakistan New York Branch
Washington, D.C.— The Federal Reserve Board on Monday announced an enforcement action against Lineage Financial Network, LLC and its owner and operator, Lance Wilson. The Board also announced that it has terminated consent orders previously issued against National Bank of Pakistan and its New York branch.
Lineage Financial Network
The Board’s order requires Lineage Financial Network and Wilson to cease and desist from violating the Bank Secrecy Act (BSA) and its implementing regulations. The order also prohibits Lineage Financial Network and Wilson from participating in any banking activity, including providing financial services to customers.
The Board found that Lineage Financial Network and Wilson failed to implement and maintain an effective anti-money laundering (AML) program, as required by the BSA. Specifically, the Board found that:
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Lineage Financial Network and Wilson failed to conduct adequate customer due diligence, including failing to obtain and retain sufficient identifying information for customers.
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Lineage Financial Network and Wilson failed to monitor transactions for suspicious activity, including failing to file suspicious activity reports (SARs) with the Financial Crimes Enforcement Network (FinCEN).
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Lineage Financial Network and Wilson failed to provide adequate training to employees on AML requirements.
The Board’s order requires Lineage Financial Network and Wilson to take a number of corrective actions, including:
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Developing and implementing an effective AML program that complies with the BSA and its implementing regulations.
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Conducting adequate customer due diligence and monitoring transactions for suspicious activity.
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Providing adequate training to employees on AML requirements.
National Bank of Pakistan
The Board terminated the consent orders that were previously issued against National Bank of Pakistan and its New York branch. The consent orders were issued in 2015 and 2016, respectively, and required the banks to take a number of corrective actions to address deficiencies in their AML programs. The Board found that the banks have taken the necessary corrective actions and are now in compliance with the BSA and its implementing regulations.
Additional Information
The Board’s enforcement action against Lineage Financial Network and Wilson is part of its ongoing efforts to combat money laundering and terrorist financing. The Board’s termination of the consent orders against National Bank of Pakistan and its New York branch reflects the banks’ progress in addressing the deficiencies in their AML programs.
For media inquiries, please contact Michelle Smith at 202-452-2955.
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