These proceedings arise out of Wells Fargo Advisors' failure to file or timely file a number of Suspicious Activity Reports ("SARs") from approximately March 2012 through June 2013. The majority of these failures involved the failure to timely file SARs on ongoing suspicious activity that continued after an initial SAR filing by Wells Fargo Advisors on related suspicious activity. At the time, Wells Fargo Advisors' anti-money laundering ("AML") policies and procedures required the filing of SARs pursuant to the requirements of the Bank Secrecy Act ("BSA"), including the filing of SARs related to continuing suspicious activity. Despite these requirements, Wells Fargo Advisors failed to file or timely file at least 50 SARs, a majority of which related to continuing suspicious activity occurring in accounts held at Wells Fargo Advisors' U.S. branch offices that focused on international customers. By failing to file or timely file SARs as required, Wells Fargo Advisors willfully violated Section 17(a) of the Exchange Act and Rule 17a-8 thereunder.

(a) Conduct, or cause to be conducted, a review of the policies, procedures and practices for the identification, evaluation, and reporting of suspicious activity related to accounts of Wells Fargo Advisors, as conducted by the designated AML financial crimes investigations unit ("FCI") to determine whether AML investigative staff have sufficient time and resources to research account activity, formulate conclusions and timely file SARs;

(b) As a result of the review, update the internal policies, procedures and practices relating to the identification, evaluation and reporting of suspicious activity related to accounts at Wells Fargo Advisors;

(c) Provide additional training with respect to the appropriate determination of when to file SARs on suspicious activity to AML investigations staff within FCI who are responsible for conducting suspicious activity investigations and filing SARs relating to accounts at Wells Fargo Advisors; and

(d) Certify, in writing to the Commission staff its compliance with the undertakings set forth above. . .