The Federal Reserve has had a longstanding practice of considering an applicant’s compliance with anti-money laundering laws in evaluating various applications, including bank mergers and acquisitions of insured depositories by bank holding companies as well as applications filed by foreign banks to establish U.S. banking offices under the Foreign Bank Supervisory Enhancement Act.
The USA Patriot Act included a provision memorializing our practice in the application area and required the Board to take into account the effectiveness of an applicant’s BSA compliance program when it considers applications under various laws.