<p>In September 2023, FinCEN assessed a $15 million civil money penalty against Bancr&eacute;dito International Bank and Trust Corporation for willful violations of the Bank Secrecy Act (BSA). This marked FinCEN&rsquo;s first enforcement action against a Puerto Rican International Banking Entity (IBE) and highlighted significant lapses in anti-money laundering (AML) compliance. <a alt="https://www.fincen.gov/news/news-releases/fincen-announces-15-million-civil-money-penalty-against-bancredito-international?utm_source=chatgpt.com" href="https://www.fincen.gov/news/news-releases/fincen-announces-15-million-civil-money-penalty-against-bancredito-international?utm_source=chatgpt.com" rel="noopener" target="_blank">FinCEN.gov</a></p>

<p><strong>Allegations in the Lawsuit</strong></p>

<p>Bancr&eacute;dito Holding Corporation, the sole shareholder of Bancr&eacute;dito, has filed a lawsuit against three international law firms&mdash;McConnell Vald&eacute;s LLC, Holland &amp; Knight LLP, and McDermott Will &amp; Schulte LLP. The lawsuit alleges that the firms provided negligent legal advice during negotiations with FinCEN, leading the bank to abandon valid defenses and agree to a Consent Order that admitted to facts known to be false. The complaint seeks compensation for the damages incurred due to the alleged legal malpractice. <a alt="https://www.prnewswire.com/news-releases/bancredito-holding-files-lawsuit-over-legal-advice-that-led-to-multi-million-dollar-fine-302559051.html?utm_source=chatgpt.com" href="https://www.prnewswire.com/news-releases/bancredito-holding-files-lawsuit-over-legal-advice-that-led-to-multi-million-dollar-fine-302559051.html?utm_source=chatgpt.com" rel="noopener" target="_blank">PR Newswire</a></p>

<p><strong>Legal Proceedings</strong></p>

<p>The lawsuit was filed in the Eleventh Judicial Circuit Court of Miami-Dade County. Bancr&eacute;dito Holding Corporation is seeking a jury trial and damages for the alleged legal malpractice. The outcome of this lawsuit could have significant implications for the bank&#39;s future operations and its relationship with legal advisors.</p>

<p><strong>Implications</strong></p>

<p>This legal action underscores the importance of sound legal counsel in navigating complex regulatory environments. The outcome of the lawsuit may influence how financial institutions approach compliance and legal advisory services in the future.</p>