Riggs’ system of internal controls was inadequate to ensure ongoing compliance
with the BSA across all business lines. Riggs’ internal controls were not designed to take
into account the exposure posed by the customers, products, services, and accounts from
high-risk international geographic locations that are commonly viewed as high-risk for
money laundering. Indeed, Riggs’ internal controls proved insufficient to detect and
monitor risk, or to alert the bank to the need to take preventive or corrective action when
the risk materialized.
Riggs did not implement an effective system to identify and assess the BSA/AML
risk present throughout the institution. The risk matrices used in some of Riggs’
divisions all contained similar criteria, rather than being tailored to the particular lines of
business on a risk-graded basis, which weakened their effectiveness. As a result,
management was unable to define and analyze concentrations of risk in the accounts,
customers, locations, and products of Riggs.
2Riggs’ customer due diligence program was weak and was not implemented in an
effective or consistent manner. Certain areas of Riggs failed to acquire or to use the
bank’s account opening and customer activity information collection procedures.
Further, customer due diligence information required by Riggs’ policies and procedures
was frequently missing. As a result, Riggs failed to identify a large number of accounts
associated with the governments of two foreign countries. Moreover, Riggs’ enhanced
due diligence policies and procedures governing high-risk areas were weak or, in some
cases, nonexistent. High-risk areas include high-risk transactions such as transactions
payable upon proper identification (“PUPID”), high-risk customers such as check cashers
and money remitters, and accounts involving high-risk international geographic locations
including international private banking, embassy banking, politically exposed persons,
and non-resident aliens. On two occasions, although Riggs’ management said that the
institution had discontinued PUPID transactions, Riggs allowed the transactions to
continue.
Riggs also failed to implement adequate internal controls to ensure the
identification of suspicious transactions and the timely filing of complete suspicious
activity reports (“SARs”) on reportable transactions. Riggs did not effectively use
procedures and automated technology already in place to identify and review suspicious
cash, monetary instruments, or wire activity. Riggs did not have procedures or internal
controls to ensure that subpoenas and other government requests regarding
accountholders were referred to the division responsible for investigating potential
suspicious activity.
Finally, internal controls were lacking in Riggs’ management of its largest
banking relationship, which involved the accounts of a foreign government, its politically
exposed persons, and the companies owned by such persons (described section III.C.3.
below). There was insufficient staff and procedures to monitor the accounts and a lack of
oversight over the account relationship manager and his staff. These problems continued
even after numerous warning signs indicated that Riggs needed to take corrective action.