For an example of how corrupt management and poor internal controls can undo a financial institution, look to West Virginia's now-defunct First National Bank of Keystone.
AML-related enforcement actions issued by the OCC have more than halved since 2005, from 32 actions in 2005 to 12 during the first three quarters of 2007, as the number of terminated actions have more than double in the same period, Dan Stipano, the agency's deputy chief counsel, said.