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bancredito

Abandonment, Conflicted Loyalties, and Lost Opportunities: How Trusted Counsel Became Bancrédito’s Undoing

Bancrédito’s downfall came not from fraud or insolvency but from the actions of its own legal advisors. Once deemed compliant, the bank collapsed within two years, ending in receivership and a $15 million FinCEN penalty.

Published on17th September 2025
Abandonment, Conflicted Loyalties, and Lost Opportunities: How Trusted Counsel Became Bancrédito’s Undoing
Published: 17th September 2025

FinCEN quietly opened a federal BSA investigation in late 2019. Bancrédito retained Kobre & Kim to open a dialogue in Washington, while H&K and McConnell continued to run point before Puerto Rico’s regulator, OCIF. For eighteen months FinCEN stayed silent; H&K and McConnell treated the federal risk as remote and concentrated on beating back OCIF’s ever‑expanding document demands.


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