In our examination of two recent OCC BSA/AML consent orders, one with a bank and another with an individual in-house professional, we review the OCC’s allegations underlying the orders and how the OCC focuses on the core pillars of BSA/AML compliance when choosing to pursue enforcement.  We also discuss the takeaways for boards and management of financial institutions when accepting higher-risk customers, including digital currency exchanges, and what the AML liability risk is for individuals – including how such risk can be minimized, and the inherent tension between the interests of institutions and their executives and compliance officers.  Finally, we discuss how the use of third-party consultants and advisors regarding AML compliance can be a double-edged sword for financial institutions and individuals facing downstream enforcement actions.

Click here to listen to the podcast.   For more information on BSA/AML compliance, visit Money Laundering Watch, a blog on which members of Ballard Spahr’s White Collar Defense/Internal Investigations Group regularly report on BSA/AML developments.