Old National Bancorp was in the midst of its 2011 regulatory examination when the company's chief risk officer, Candice Rickard, learned there might be a problem. The Evansville, Ind.-based bank had received sparkling reviews on its Bank Secrecy Act compliance for five years in a row, yet this year things had gotten rougher. Now, Old National was on the cusp of receiving a consent order from the Comptroller's office, requiring it to beef up its anti-money-laundering program.

"It was a shock for us," Rickard recalls. "The message was, 'You were fine before, but now you're all broken.' Nothing had really changed except they were raising the bar. Expectations were higher, and they literally brought it to us in the format of an unsatisfactory review."

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