In its written order assessing a $24 million Bank Secrecy Act penalty on Arab Bank of New York the U.S. Financial Crimes Enforcement Network criticized the bank for not using "publicly available information, to monitor and identify" funds transfers that warranted further investigation. FinCEN said the names of the persons conducting the transfers "appeared in credible sources of publicly available information." FinCEN's order in August also said the bank "should have developed procedures for utilizing - to the extent appropriate and practical - publicly available information concerning beneficiaries and originators, on a risk-assessed basis…The sources include…Congressional testimony, indictments in the...
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