Bank Of San Juan Internacional, Inc. And The U.S. Attorney’s Office For The District Of Puerto Rico Resolve Pending Litigation And Related Matters

SAN JUAN, P.R. – Bank of San Juan Internacional, Inc. (“BSJI”) and the United States Attorney’s Office for the District of Puerto Rico (“USAO-PR”) have resolved pending investigations and litigation and matters related to that litigation. The litigation stemmed from a federal investigation of BSJI that involved the search of BSJI’s offices in February 2019, and the subsequent seizure of $53,082,824.19 from BSJI and related accounts. The funds were seized based on their connection to certain sophisticated financial transactions (“Financial Transactions”) and underlying agreements to which BSJI was a party. The litigation also involved the USAO-PR filing of a civil forfeiture action relating to those funds. The federal investigation by the USAO-PR further involved review of BSJI’s practices with respect to compliance with the Bank Secrecy Act (“BSA”), including laws and regulations relating to BSJI’s actions, policies and procedures with respect to the filing of suspicious activity reports (“SARs”).

During the period following the February 2019 searches and the seizure of funds from BSJI, Counsel for BSJI and the USAO-PR met and exchanged information regarding the facts underlying the investigation and litigation. BSJI provided to the USAO-PR a comprehensive explanation of the Financial Transactions and relevant facts known to it regarding those Financial Transactions, including the background to, and the mechanics and accounting governing, the Financial Transactions. BSJI cooperated fully in the investigation, agreed to requests from the USAO-PR for information and provided access to its subject matter experts and counsel.

After a thorough review and careful consideration of the information and materials BSJI provided to the USAO-PR with respect to the Financial Transactions, the USAO-PR agreed that dismissal of the civil forfeiture action and returning of the seized funds ($53,082,824.19) to BSJI was appropriate and warranted. As a result, on February 5, 2020, the USAO-PR dismissed the civil forfeiture action, will return all seized funds to BSJI, and has ended its investigation of BSJI and its officials.

In addition to providing the USAO-PR with information and materials relating to the Financial Transactions, BSJI has represented that, as of February 2019, BJSI engaged in numerous substantive measures to strengthen its governance, risk management and control procedures.

As noted above, the USAO-PR conducted an investigation of BSJI regarding its BSA compliance and BSJI’s activities relating to the filing of SARs. In connection with the USAO-PR’s BSA investigation, BSJI has acknowledged that it had opportunities to improve governance, risk management and controls with respect to its BSA compliance and the filing of SARs with respect to a number of depositor account-holders. In turn, the USAO-PR has acknowledged (and taken into consideration in reaching an agreement) the corrective actions BSJI has undertaken in order to improve its BSA and Anti-Money Laundering policies and procedures. As part of the agreement to resolve the USAO-PR’s BSA investigation, BSJI has agreed to pay to the USAO-PR the sum of $1,000,000.

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