When Lawyers Switch Sides on Their Own Client: The $15 Million Lesson of Bancrédito
Bancrédito, a small Puerto Rican bank, faced a $15 million penalty for willfully failing to report suspicious transactions despite earlier legal assurances. This case highlights the costly consequences of compliance failures and legal misadvice.
Bancrédito International Bank & Trust was a small Puerto Rican bank with a special offshore license. Like all banks, it had to follow the Bank Secrecy Act (BSA) and anti-money-laundering (AML) rules: laws designed to catch shady transactions and make sure suspicious activity reports (SARs) are filed when money looks questionable. In 2020, Bancrédito’s lawyers—respected firms from San Juan and Miami—told regulators in writing that the bank’s compliance program was “adequate” and risk-based.
They even stressed that filing SARs is a matter of judgment, not guesswork. In other words: the bank was doing what the law required. Those lawyers helped negotiate a settlement with Puerto Rico’s banking watchdog, which ended with a slap on the wrist: a $97,000 fine and a plan for improvements.
For a bank, that’s like paying a speeding ticket—not pleasant, but survivable.
Sept. 17, 2025
