On February 7, 2018, Rabobank National Association (“Rabobank”), a U.S. subsidiary of Netherlands-based Cooperative Rabobank U.A., pleaded guilty to one count of conspiracy to defraud the United States and to corruptly obstruct the examination of a financial institution.  According to court filings, Rabobank executives conspired to conceal significant deficiencies in the bank’s Bank Secrecy Act (“BSA”) and anti-money laundering (“AML”) program and to obstruct a periodic examination of Rabobank’s Southern California operations by the Office of the Comptroller of the Currency (“OCC”) between 2012 and 2013.  In connection with its plea, Rabobank admitted that its deficient BSA/AML program allowed hundreds of millions of dollars in cash from Mexico and elsewhere to be deposited at rural branches and wired or otherwise transferred back out of accounts without sufficient investigation or required reporting.  Rabobank agreed to forfeit more than $368.7 million in connection with its guilty plea and to cooperate with DOJ’s ongoing investigation.  The bank was previously sanctioned by the OCC in 2006 and 2008 for similar failures.  In December 2017, former Rabobank executive George Martin entered into a deferred prosecution agreement in connection with his role in the conspiracy. United States v. Rabobank NA, 18-cr-0614 (S.D. Cal.)

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