“On a number of events previous to November 2022, Lane and Fraher – and thru them SCC – turned conscious that the Financial institution had severe deficiencies in its BSA/AML compliance program,” the grievance mentioned. “As well as, by the outcomes of a number of examinations of Silvergate by the Federal Reserve, by the Federal Reserve Financial institution of San Francisco (the ‘FRBSF’), Lane and Fraher ought to have identified that there existed vital deficiencies within the Financial institution’s BSA/AML compliance program.”
