The Federal Reserve Board announced on 8 August 2024 that the Federal Reserve Bank of Philadelphia had entered into a written agreement, dated 5 August 2024, with Customers Bancorp, of West Reading, Pennsylvania, and its banking subsidiary, Customers Bank, of Malvern, Pennsylvania, following examinations and an inspection that identified deficiencies in the bank's compliance with Bank Secrecy Act and anti-money laundering requirements, as well as failures in its obligations under the Office of Foreign Assets Control sanctions regime.
The agreement does not cite any violations of law and imposes no monetary fine, but it carries a set of binding compliance obligations. The agreement requires the bank's board to strengthen its oversight of the bank's major operations and activities, explicitly including its digital asset strategy.
DIGITAL ASSETS AND LOOK-BACK REVIEW
The written agreement specifically references the bank's digital asset strategy and its instant payments platform, which allows commercial clients to make tokenised payments to each other over a distributed ledger system.
The Fed required the bank to engage an independent third party to conduct a look-back review of suspicious transactions associated with high-risk clients during the period from March 2023 to August 2023.
COMPLIANCE REQUIREMENTS
Among the agreement's requirements is that the bank's BSA/AML compliance programme be managed by a qualified BSA/AML compliance officer with adequate resources, training and staffing.
A written agreement is a formal, public enforcement action that sits below a cease-and-desist order in severity.
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