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From the perspective of financial stability, neither model in all cases reduces the probability of failure or the cost of failure of a banking group. The branch structure may provide an affiliate (or parent) and, hence, the group as a whole with greater ability to withstand adverse shocks that do not threaten the viability of the group, because it enables the banking group to more easily mobilize and re-direct funds from healthy affiliates to other affiliates (or parent) that suffer losses. At the same time, the branch structure also obligates the group to cover fully all losses generated in branches | UNITED STATES OF AMERICA DEPARTMENT OF THE TREASURY FINANCIAL CRIMES ENFORCEMENT NETWORK IN THE MATTER OF RIGGS BANK N.A. No. 2004-01 ASSESSMENT OF CIVIL MONEY PENALTY I. INTRODUCTION The Secretary of the United States Department of the Treasury has delegated to the Director of the Financial Crimes Enforcement Network FinCEN the authority to determine whether a financial institution has violated the Bank Secrecy Act 31 USC 5311 et seq. and 31 CFR Part 103 thereunder BSA and what if any sanction is appropriate. In order to resolve this matter and only for that purpose Riggs Bank N.A. Riggs has entered into a CONSENT TO THE ASsEssMeNT of civil money PENALTY CONSENT dated May 13 2004 without admitting or denying FinCEN s determinations described in Sections III and IV below except as to jurisdiction in Section II below which is admitted. The CONSENT is incorporated into this ASSESSMENT OF CIVIL MONEY PENALTY ASSESSMENT by this reference. II. JURISDICTION Riggs is the principal subsidiary of Riggs National Corporation a publicly traded bank holding company based in Washington D.C. As of December 31 2003 Riggs had assets of approximately 6 billion deposits of 4.29 billion and stockholders equity of 427.2 million. Riggs is a financial institution and a bank within the meaning of 31 USC 5312 a 2 and 31 CFR 103.11. The Office of the Comptroller of the Currency the OCC is Riggs primary federal supervisory agency and examines Riggs for BSA compliance. III. FINDINGS A. Summary of Violations FinCEN has determined that Riggs willfully violated the suspicious activity and currency transaction reporting requirements of the BSA and its implementing regulations and that Riggs has willfully violated the anti-money laundering program AML program requirement of the BSA and its implementing regulations. The violations Riggs engaged in were systemic - Riggs was deficient in designing a program tailored to the risks of its business that would ensure appropriate reporting implementing the
