Gibraltar Case Study

Gibraltar Private Bank & Trust is one of the top 10 largest banks by assets in Florida.
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Case Study

Gibraltar Case Study

Gibraltar’s past compliance troubles have been well-documented and widely reported. As recently as 2016, Gibraltar of Coral Gables was hit with a grand total of $4 million in fines related to BSA violations. The Financial Crimes Enforcement Network (FinCEN) fined them $1.5 million for failing to file suspicious activity reports (SARs) related to over $500 million in transactions. Not only was Gibraltar fined by FinCEN, but separately by the Office of the Comptroller of the Currency (OCC) for $2.5 million. In 2014 they were placed under consent order and advised to address certain deficiencies in their compliance program.
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How we solved problem

Gibraltar Private Bank & Trust implemented Global RADAR as part of their plan to address their remediation efforts to ensure clients were properly risk rated and that the high-risk clients Know Your Customer profiles were comprehensive. While all operational requirements were met, added system functionality ensured that clients were properly risk rated.

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The result

Following the deployment of Global RADAR, Gibraltar’s Know Your Customer / Customer Due Diligence process and risk-rating remediation project was a success. Addressing the deficiencies of the consent order related to KYC/CDD with this tool, ensuring that client profiles were adequate, lead to the eventual lifting of the consent order. 

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