Why bank that warned UMN Iranian students is being fined

This announcement just came in from TCF Bank.

It apparently has to pay a fine of $10 million for failing to comply fully with the Bank Secrecy Act. (The act essentially requires banks to help the feds prevent money laundering.)

I wonder whether it’s in any way a backdrop to the bank’s threatened closure last month of the accounts of some Iranian students from the University of Minnesota.

I’ve got a call in to the bank.

UPDATE: This is from the Office of the Comptroller of the Currency, the agency that levied the fine:

The Office of the Comptroller of the Currency (OCC) today announced a $10 million civil money penalty (CMP) against TCF National Bank, Sioux Falls, S.D., for violations of the Bank Secrecy Act (BSA).

An OCC examination of the bank’s account and transaction activity between November 2008 and July 2010 revealed late filing of suspicious activity reports (SARs). The suspicious activities primarily consisted of cash transactions which indicated structuring and wire transfers where the source and purpose of the funds were unknown. In addition, upon further investigation, OCC found instances where SARs failed to adequately explain or identify potential terrorist financing.

The CMP follows a cease and desist order issued in July 2010 which directed the bank to correct deficiencies in its BSA and anti-money laundering programs and required an independent examination of BSA reports filed between November 2008 and July 2010.

Here’s the bank’s release:

TCF National Bank (“TCF Bank”), the principal subsidiary of TCF Financial Corporation (“TCF”) (NYSE: TCB), today announced that it has entered into an agreement with the Office of the Comptroller of the Currency (“OCC”) pursuant to previously disclosed deficiencies in its Bank Secrecy Act (“BSA”) compliance program. TCF Bank previously disclosed that it may incur a civil money penalty related to its BSA program. TCF Bank has agreed to payment of a civil money penalty in the amount of $10.0 million, or 6 cents per common share in the fourth quarter of 2012. TCF Bank believes that this settlement, along with comprehensive changes it has made to strengthen its BSA compliance program, is a significant step towards a satisfactory resolution of its July 2010 BSA-related consent order with the OCC.

“TCF, bank regulators and law enforcement all share the same goal – ensuring the continued safety and security of the deposits of our customers – and we are confident that with the help of the OCC, we have taken the necessary steps to put in place a best-in-class BSA program and team to lead this critical area moving forward,” said William A. Cooper, TCF Chairman and Chief Executive Officer. “We appreciate the OCC’s guidance in helping us strengthen our BSA program and take great pride in our ability to assist regulators and law enforcement in improving the safety of the banking system.”

In cooperation with the OCC, TCF Bank has devoted considerable effort and resources over the past two years – ranging from enhanced training to screening-system improvements – to strengthen its BSA compliance program aimed at monitoring, detecting and reporting suspicious activities, as well as its other legal and regulatory requirements.