FinCEN and OCC Assess Concurrent $5 Million Civil Money Penalties Against Doha Bank New York Branch for BSA Violations

In April 2009, the Financial Crimes Enforcement Network (FinCEN) and the Office of the Comptroller of the Currency (OCC) each assessed concurrent civil money penalties of $5 million against the New York branch of Doha Bank Q.P.S.C. for Bank Secrecy Act (BSA) violations. The branch consented to payment without admitting or denying the allegations; total liability was satisfied by a single $5 million payment to the U.S. Treasury because the penalties were structured concurrently.

Exact day in April 2009 needs verification against FinCEN’s press-release archive; frontmatter date set to 2009-04-01 as placeholder. Needs-exact-date.

Cited Findings

Per the public FinCEN and OCC assessments:

• Compliance program failure: The branch failed to maintain a BSA compliance program reasonably designed to ensure BSA recordkeeping and reporting compliance
• Suspicious-activity monitoring failure: Failure to adequately identify, research, report, and monitor suspicious activities occurring through the branch’s funds transfers, pouch activity, demand draft services, and correspondent relationships
• Foreign-correspondent due-diligence failure: Failure to conduct sufficient due diligence on foreign correspondent accounts
• Unfiled SARs: Failure to file more than 500 required Suspicious Activity Reports across the examination period (May 1, 2004 through January 16, 2007)
• Audit failure: Inadequate audit and independent testing of the BSA program
• Internal-controls failure: Inadequate internal controls, resulting in an “extended period” of SAR-reporting violations that impaired the usefulness of those reports to law enforcement

Antecedent: 2006 Cease-and-Desist Order

In September 2006, the OCC had issued a Cease and Desist Order (by consent) to the New York branch based on BSA program deficiencies. That order mandated the transaction look-back covering May 1, 2004 through January 16, 2007; the look-back was completed in January 2008. The April 2009 civil money penalty formalized the monetary consequence of the deficiencies the look-back surfaced.

Why This Matters

The April 2009 action is the public baseline for U.S. regulatory concerns about Doha Bank’s correspondent-banking posture and foreign-correspondent due-diligence practices. It predates the 2019 UK High Court terrorism-financing filing against the bank (2019-07-30–bb-and-others-v-doha-bank-uk-filing) by ten years. The bank’s New York branch gives Doha Bank direct access to U.S. dollar clearing, and the 2009 action documents that — as of the 2004-2007 examination window — the branch’s systems were not capturing suspicious activity at the volume and with the specificity U.S. regulators required.

Whether subsequent remediation has resolved these deficiencies, or whether post-2009 transactions related to the Al-Khayyat brothers or Power International Holding generated any non-public SAR activity, is not disclosed in public records as of April 2026.

Related Entries

• doha-bank
• al-khayyat-brothers
• power-international-holding
• 2019-07-30–bb-and-others-v-doha-bank-uk-filing
• 2023-03-08–bb-v-doha-bank-court-of-appeal-state-immunity
• 2026-01-05–bb-v-doha-bank-dismissed-failure-to-prosecute