Regulators Provide Greater Transparency into BSA/AML Enforcement Process.  On August 13, 2020, the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency (the “Agency” or collectively the “Agencies”) issued a joint statement updating and clarifying their 2007 guidance regarding how they evaluate enforcement actions

The COVID-19 pandemic has created a perfect storm for money laundering and fraud.  Financial institutions subject to the Bank Secrecy Act are facing increased incidents of fraud and must catch and report suspicious or illegal activity while juggling financial concerns and trying to work remotely.  The pandemic also will expose existing incidents of fraud—and

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

AML/BSA compliance continues to be the focus of rigorous enforcement on both the federal and state levels.  In this episode, we look at the conduct for which financial institutions have been faulted in recent enforcement actions, flag other missteps that can trigger regulatory scrutiny, and offer practical tips for avoiding regulatory criticism and reducing enforcement