Bank Secrecy Act
In re: Eagle Bank
Date: June 30, 2026
Issue: EagleBank’s non-prosecution agreement with the U.S. Department of Justice (DOJ) to resolve allegations that it violated the Bank Secrecy Act (BSA) by willfully failing to implement an anti-money laundering (AML) program and permitting a fraudulent check scheme.
Case Summary: EagleBank agreed to pay more than $9.7 million under a non-prosecution agreement with the DOJ to resolve an investigation into alleged BSA violations.
The DOJ alleged that from approximately 2010 through 2021, EagleBank failed to maintain an effective AML program as required by the Bank Secrecy Act. According to the DOJ, EagleBank knowingly allowed certain favored clients to operate a check kiting scheme, a form of fraud that takes advantage of the delay in check processing, due in part to the then-CEO and chairman and the then-chief credit officer “repeatedly over[riding] the efforts of compliance personnel to close the accounts and end the illicit conduct.” EagleBank compliance staff reported the fraud concerns to the government through suspicious activity reports (SARs) within days of the account in question being opened in 2010.
In addition, the DOJ alleged that EagleBank failed to establish effective internal controls for high-risk customers and did not adopt clear procedures for deciding when to close accounts linked to repeated suspicious activity. Although employees repeatedly recommended closing the customers’ accounts and filed multiple SARs over more than a decade, EagleBank allegedly kept the accounts open because of the customers’ lending relationship.
Under the non-prosecution agreement, EagleBank agreed to pay approximately $9.7 million to resolve the allegations and strengthen its AML program by reviewing and enhancing its internal controls, policies, and procedures to ensure compliance with the BSA and other applicable AML laws. EagleBank must also implement any extra measures needed to detect and deter future violations and certify to the DOJ that it has fulfilled its compliance obligations.
Bottom Line: EagleBank said that it is committed to fully complying with all obligations of the agreement.
Document: Agreement
