OCC Enforcement Actions Against First Abu Dhabi Bank

The American Office of the Comptroller of the Currency (O.C.C.) released new enforcement actions against First Abu Dhabi Bank U.S.A. in Washington DC for violating the laws and allowing suspicious transactions within its branches.

The O.C.C. said that from 2016 to 2019, the Branch failed to adopt and implement a compliance program that adequately covered the required BSA/AML program elements, and the Branch failed to timely file Suspicious Activity Reports (“S.A.R.s”) related to suspicious customer activity.

The O.C.C. elaborated that some of the critical deficiencies in the elements of the Branch’s BSA/AML compliance program that resulted in a violation of 12 C.F.R. § 21.21, included the following:

The First Abu Dhabi Branch had an inadequate system of internal controls, ineffective independent testing, a weak B.S.A. Officer function, and insufficient staffing and training.

The Branch had systemic deficiencies in its transaction monitoring systems 3 and alert management processes, which resulted in monitoring gaps. These systemic deficiencies resulted in alert and investigation backlogs and led to a failure to file S.A.R.s in a timely manner.

The Branch had systemic deficiencies in its customer due diligence, enhanced due diligence, and customer risk rating processes.

The Branch failed to file the necessary S.A.R.s concerning suspicious customer activity in a timely manner, in violation of 12 C.F.R.

The Branch failed to adopt and implement adequate due diligence programs for foreign correspondent accounts, in violation of 31 C.F.R.

And thus, the Branch shall make payment of a civil money penalty in the total amount of five million dollars ($5,000,000.00), which shall be paid upon the execution of the Order.

Last month, Emirates Leaks revealed disclosed information on a channel in which the U.A.E. regime funds Al-Qaeda in Yemen to carry out criminal assassinations via the same bank, First Abu Dhabi Bank.

A reliable Yemeni source who used to work at the bank revealed that vast amounts of money were noticed through the transactions going to Al-Qaeda in Yemen. And ever after his resignation, he had been threatened and intimidated by various pro-UAE authorities in Yemen, so he fled the country fearing for the safety of his family. These transactions via the Emirati bank entailed assassinations and murders of innocent people and bombings in civil areas.

However, First Abu Dhabi Bank was also responsible for funding youth institutions that promote violence and extremism in Europe. One of the foreign companies that were supported by the bank is Offshore, which funds educational project that is a cover to suspicious activities, which resulted in terrorism and killing of innocent civilians.

Earlier, an investigation conducted by CNN had revealed that the U.A.E. had transferred American-made weapons to Al-Qaeda and militias in Yemen. The investigation also revealed that part of these American weapons also reached the hands of the Houthis, which would disclose sensitive details of some U.S. military technology to Tehran, and potentially endanger the lives of U.S. forces in other conflict areas.

CNN’s investigation pointed out that the U.A.E. used American weapons to buy the loyalty of Yemeni militias and tribes to influence the complex political scene, according to field leaders and analysts.

Moreover, the Associated Press unveiled, last August, that the U.A.E. had concluded secret agreements with Al-Qaeda fighters and paid them money to leave major areas and agreed with them to join its militia.

On several occasions, officials in the legitimate government in Yemen confirmed that they have evidence of a cooperative relationship between the U.A.E. and both al-Qaeda and ISIS terrorists.