On 24th July, KYC 360 reported that the OCC, regulator of national banks, has disclosed a $50,000 civil monetary penalty against Daniel Weiss, the former general counsel of Rabobank NA for concealing a critical report on the lender’s AML programme.  In 2018, the OCC and the California unit of the Dutch lender agreed a $368 million forfeiture order, in addition to a $50 million penalty that was credited toward an AML-related DoJ fine.  However, Weiss and other executives were aware of the bank’s troubles as early as 2012, when the institution’s incoming chief compliance officer informed them of previously unidentified compliance deficiencies, the OCC said.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s