23 September 2014

The submission to the US Department of the Treasury’s FinCEN bureau in Washington DC is underway. This is in line with the 60-day period allowed for a response to FinCEN’s notice of finding and notice of proposed rulemaking issued in July.

A 28-page public statement has been submitted on behalf of the Bank by Hogan Lovells, its international lawyers. A copy of this statement is available here.

The statement makes clear that the forensic accountants from Ernst and Young, in their assessment of FBME’s compliance programme, observed that the Bank’s procedures “incorporates the requirements” of the EU’s Third Money Laundering Directive and the fourth issue of the Central Bank of Cyprus’s directive to credit institutions in accordance with Article 59(4) of the Prevention and Suppression of Money Laundering Activities of 2007 to 2013.

The statement continues, ‘EY’s assessment further reported that FBME has “protocols in place that allow the Bank to continuously keep the Program aligned with these legal requirements”.’

FBME has restated its commitment to continuing to cooperate with the governments of the US, Cyprus and Tanzania in the fight against money laundering and terrorist financing. Recommendations have been made in areas where its compliance programme can be improved, which the Bank has already committed to implementing.