While working as a Federal Deposit Insurance Corp. bank examiner in the 1970s, Joe Gunnell got a call from a nervous bank compliance officer who asked for guidance on whether transactions involving an out-of-state used car dealership might be suspicious. The case was loaded with obvious red flags, Gunnell recalls, so concerned FDIC examiners decided to take a closer look at the bank's anti-money laundering program. They uncovered a number of fraudulent transactions that had flown under the bank's radar. In the end, the bank was cited for a weak compliance program and forced to repay hundreds of thousands of...
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