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.