February 27 2017
The Financial Crimes Enforcement Network (FinCEN) has determined that grounds exist to assess a civil money penalty against Merchants Bank of California, N.A. (Merchants or the Bank), pursuant to the Bank Secrecy Act (BSA) and regulations issued pursuant to that Act.1 Merchants admits to the facts set forth below and that its conduct violated the BSA. 2 Merchants consents to this assessment of a civil money penalty and entered into the CONSENT TO THE ASSESSMENT OF CIVIL MONEY PENALTY (CONSENT) with FinCEN. FinCEN has determined that the penalty in this matter will be $7 million.