In remarks at an anti-money laundering and financial crime conference in March, the Department of Justice's Assistant Attorney General Leslie Caldwell urged banks to alert authorities if tellers feel a large withdrawal seems suspicious. If they don't, criminal charges could be filed.

"The vast majority of financial institutions file Suspicious Activity Reports when they suspect that an account is connected to nefarious activity," Caldwell said. "But, in appropriate cases, we encourage those institutions to consider whether to take more action: specifically, to alert law enforcement authorities about the problem, who may be able to seize the funds, initiate an investigation, or take other proactive steps."

No specifics were given of what constitutes "appropriate cases."

Caldwell firmly stated that the DoJ expects banks to take the request seriously and begin its implementation despite it not being a "profit center." However, it was promised, "[I]nvestment in compliance will pay off – and it’s the right thing to do."

For banks that aren't compliant, Caldwell said the DoJ will then enter into deferred prosecution agreements or non-prosecution agreements with the institution.

"DPAs and NPAs are useful enforcement tools in criminal cases," Caldwell said. "And these agreements have teeth – not just because they are overseen by the Department of Justice and sometimes a court, but because of the potential penalties triggered by a breach."

She continued:

Let me be clear: in the Criminal Division, we will hold banks and other entities that enter into DPAs and NPAs to the obligations imposed on them by those agreements. And where banks fail to live up to their commitments, we will hold them accountable. 

In those cases, Caldwell promised, the DPAs or NPAs will be torn up without hesitation and criminal charges will be filed.

Closing, Caldwell said:

I strongly encourage the representatives of banks and other financial institutions participating in this conference to take the opportunity -- both during the next few days and once you return to your respective offices -- to reflect on whether your institutions have effective anti-money laundering programs and other compliance policies and practices to prevent or mitigate financial crime. The integrity and viability of the global financial system require that you do.