September 22, 2025
Following a $15 million AML penalty against Bancrédito, U.S. regulators warn offshore banks to strengthen anti-money laundering programs or face stricter enforcement.
The United States financial regulatory authorities are warning offshore banks that the era of lenient oversight is ending, following the $15 million civil penalty imposed on Bancrédito International Bank & Trust Corporation by the Financial Crimes Enforcement Network (FinCEN). This enforcement action highlights the increasing scrutiny of International Banking Entities (IBEs) and other offshore lenders under U.S. anti-money laundering (AML) laws.
Bancrédito, a Puerto Rico-based institution, was found to have failed to maintain an adequate AML compliance program, including the timely filing of Suspicious Activity Reports (SARs) and insufficient due diligence for high-risk international transactions. FinCEN leveraged its “Gap Rule”, which applies to banks without a federal primary regulator, to impose the civil penalty and require the bank to surrender its International Banking Entity license.
Regulators are now signaling that the Bancrédito case is a warning for all offshore lenders, particularly those in jurisdictions with lighter regulatory oversight. Banks operating in these territories must adopt rigorous compliance programs, implement robust monitoring systems, and ensure timely reporting of suspicious transactions.
Experts note that offshore lenders often rely on a combination of local and U.S.-linked financial relationships, which exposes them to U.S. AML enforcement even if headquartered outside the continental United States. The Bancrédito fine illustrates that regulatory gaps no longer protect institutions from civil penalties or reputational damage.
The U.S. Treasury, through FinCEN, is prioritizing enforcement actions against institutions that fail to meet the Bank Secrecy Act (BSA) and anti-money laundering requirements. The Bancrédito case underscores three key areas:
Gap Rule Enforcement – Ensuring IBEs maintain proper AML programs.
Correspondent Account Oversight – Monitoring foreign transactions and high-risk jurisdictions.
Legal Accountability – Expecting that financial advisors and counsel provide guidance that prevents regulatory violations.
Offshore banks are expected to review their compliance frameworks aggressively, focusing on risk-based controls and enhanced due diligence. Analysts predict that regulators may increase audits, examinations, and enforcement actions for institutions that lag behind in AML program implementation.
Financial consultants also warn that reputational risks are just as significant as civil penalties. Banks failing to comply with AML obligations can face withdrawal of U.S. banking access, fines, and adverse publicity that could impact client relationships and investor confidence.
The U.S. crackdown following the Bancrédito $15M penalty represents a shift in AML enforcement strategy, signaling zero tolerance for compliance gaps among offshore lenders. Financial institutions operating internationally must adopt comprehensive AML programs, maintain transparent reporting, and adhere to both U.S. and local regulatory requirements to avoid similar penalties.
The Bancrédito case has become a benchmark for offshore banking compliance, demonstrating that robust internal controls and adherence to regulatory guidance are essential to protect both institutional integrity and global financial stability.
