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The Latest SERVICING Or ig i nat ion s e r v ic i ng a na ly t ic s Declaring the Bank of Delaware in violation of the Bank Secrecy Act, the FDIC and FinCEN demanded a large payment to the Treasury. T he FDIC and the Financial Crimes Enforcement Network (FinCEN) announced the assessment of $15 million in penalties against the First Bank of Delaware in Wilmington for violations of the Bank Secrecy Act (BSA) and antimoney laundering (AML) laws and regulations. According to a joint release, the civil money penalties will be satisfied by a $15 million payment to the Treasury. The agencies determined that First Bank of Delaware "failed to implement an effective BSA/ AML compliance program with internal controls" designed to detect and report evidence of money laundering and other suspicious activity. Specifically, the bank failed to adequately oversee third-party payment processor relationships and related products and services "in a manner commensurate with associated risks," the release says. "To make money, First Bank of Delaware entered into risky lines of business and chose to disregard its Bank Secrecy Act responsibilities," said Jennifer Shasky Calvery, director of FinCEN. "As a result of its failure to implement systems and controls to identify The M Report | 49 se c on da r y m a r k e t Bank Assessed $15M in Penalties for Compliance Failures and report suspicious activities, as required by the BSA, financial predators were able to victimize consumers." According to the agencies, the bank also settled civil charges (on related activities) brought by the Department of Justice, U.S. Attorney's Office for the Eastern District of Pennsylvania. On November 16, Bryn Mawr Trust Company, of Bryn Mawr, Pennsylvania, purchased approximately $80 million of the branch's loans and $70 million of its deposits. The cash transaction was completed November 19. In a release from Bryn Mawr Bank Corporation, chairman and CEO Ted Peters said the acquisition provides Bryn Mawr with a foothold to invest in opportunities in Delaware. "We look forward to welcoming our new customers and staff members," Peters said. "This acquisition allows us to open our first full-service branch in Delaware, with a critical mass of loans and deposits on day one."