FinCEN’s $15 million Bancrédito penalty: findings and significance

FinCEN announced a $15 million civil money penalty against Bancrédito International Bank and Trust Corporation on September 15, 2023 for willful violations of the Bank Secrecy Act and implementing regulations.

What the agency found

Its announcement identified suspicious-activity reporting failures, inadequate due diligence for foreign correspondent accounts and deficiencies in the bank's anti-money-laundering program. FinCEN described it as its first enforcement action against a Puerto Rican international banking entity and its first enforcement of the relevant AML “Gap Rule” requirement.

Why the distinction matters

A civil money penalty against a bank is different from a criminal sentence imposed on a person. The date also matters: this was a 2023 action, even though the original JournoPulse page was dated March 2026.

The consent order is the detailed record for assessing the findings, the relevant period and the institution's commitments. Readers should use that document when evaluating later assertions that the penalty was mistaken, settled differently or set aside.

What this article does not establish

The linked materials do not document a subsequent cancellation of the penalty. A separate pardon or private lawsuit should not be treated as evidence that the regulatory order ceased to apply. Any such change needs an identifiable official decision.

Three dates to keep together

Record the period examined, the date of the enforcement order and the date of the post discussing it. They answer different questions. A newly published commentary on an older order does not make the underlying violations newly occurring events.

A JournoPulse blog post, prepared with AI assistance from the linked sources. Our methodology · Suggest a correction.