The size of an NHL ice surface – 200 feet by 85 feet – hasn’t changed in 100 years. Yet […]
Category: AML Regulations and Enforcement Actions
2018 National Money Laundering Risk Assessment – AML 2018 Looks Very Similar to AML 2015
On December 20th the Treasury Department released its National Illicit Finance Strategy (something required under the Countering America’s Adversaries Through […]
CRA-like Evaluations for Banks’ BSA/AML Programs? Let’s Give Banks Some Credit for Building and Maintaining an Outstanding BSA Program!
The only time the public (and Congress) hears about a bank’s BSA program is when the program has failed and […]
“Extraordinary workloads” and “extraordinary steps” – What can we learn from these phrases? Unfortunately, not much
The most recent AML-related public censure comes in the form of a FINRA “AWC” or Letter of Acceptance, Waiver and […]
Bucksnort, Marijuana, Thresholds, and “a little bit of tension” … Senate Banking Committee and BSA/AML
https://www.banking.senate.gov/hearings/10/24/2018/combating-money-laundering-and-other-forms-of-illicit-finance-regulator-and-law-enforcement-perspectives-on-reform From obvious tension between FinCEN and the OCC, to patiently waiting for marijuana guidance, to missteps on CTR filings […]
The Strip Club – Is Membership Now Closed?
With today’s announcements from the US Attorney for the Southern District of New York, OFAC, Federal Reserve, New York State […]
Swiss Regulator FINMA criticizes Societe General’s lack of an EVOC – Enterprise View of the Customer
https://www.finma.ch/en/news/2018/09/20180917-mm-gwg-cs/ Not being able to impose monetary penalties, Swiss financial supervisor FINMA concluded two enforcement procedures against Credit Suisse AG. […]
ING pays record EUR 775,000,000 fine to Dutch Public Prosecution Service for multiple AML failures
Dutch prosecutors hammered ING Group for 7+ years of abject AML failures … missing and incomplete customer due diligence files, […]
Ninth Circuit rules that the FFIEC BSA/AML Examination Manual has the force of regulation!
Upsetting the long-held belief that legislation is clarified by regulations that are clarified and explained by written guidance and modified […]