Gibraltar Case Study

Gibraltar Private Bank & Trust is one of the top 10 largest banks by assets in Florida.
two businessmen people
Case Study

Gibraltar Case Study

Gibraltar’s past compliance troubles have been well-documented and widely reported. As recently as 2016, Gibraltar of Coral Gables was hit with a grand total of $4 million in fines related to BSA violations. The Financial Crimes Enforcement Network (FinCEN) fined them $1.5 million for failing to file suspicious activity reports (SARs) related to over $500 million in transactions. Not only was Gibraltar fined by FinCEN, but separately by the Office of the Comptroller of the Currency (OCC) for $2.5 million. In 2014 they were placed under consent order and advised to address certain deficiencies in their compliance program.
How we solved problem

Gibraltar Private Bank & Trust implemented Global RADAR as part of their plan to address their remediation efforts to ensure clients were properly risk rated and that the high-risk clients Know Your Customer profiles were comprehensive. While all operational requirements were met, added system functionality ensured that clients were properly risk rated.

The result

Following the deployment of Global RADAR, Gibraltar’s Know Your Customer / Customer Due Diligence process and risk-rating remediation project was a success. Addressing the deficiencies of the consent order related to KYC/CDD with this tool, ensuring that client profiles were adequate, lead to the eventual lifting of the consent order. 

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