Bob Pasley: The Importance of Due Diligence

In this segment of AML Now, John J. Byrne, ACAMS executive vice president, spoke with Bob Pasley to discuss his upcoming book Anatomy of a Banking Scandal and his career at the Office of the Comptroller of the Currency (OCC). Pasley’s book explores the failure of the First National Bank of Keystone in the late 90s and the corruption found at the local level in West Virginia.

First National Bank of Keystone, named the most profitable community bank in the country for three to four years, grew from a $17 million bank to eventually a $1.1 billion bank—all from fraudulent activity. In this segment, Pasley explains how this was made possible for a small community bank in West Virginia and how bank examiners realized something was wrong. Anatomy of a Banking Scandal is available for preorder and it will be available on May 31, 2016.

About the author: Pasley was most recently a senior vice president in the anti-money laundering (AML) policy area for Bank of America. Prior to that, he served as a contractor for the Financial Crimes Enforcement Network, working on policy issues, handling specific cases and assisting in drafting the final 312 regulation. Before that, he was an assistant director of the enforcement and compliance division of the OCC and specialized in the AML area. He is a graduate of the Cornell Law School and of the Stonier Graduate School of Banking. His honors thesis at Stonier was on the consolidation of the banking agencies. He has also written on several other topics, including a chapter on the history of the banking agencies’ enforcement powers, a law review article on the impact of the Double Jeopardy Clause on civil money penalties, a law review article on the tension between privacy rights and anti-money laundering enforcement and a law review article on developments in Bank Secrecy Act enforcement.

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