After reviewing how the AMLA expands the BSA’s goals, we look at which AMLA provisions have the most impact on BSA compliance, including the AMLA’s emphasis on information sharing, the Financial Crimes Enforcement Network’s “national priorities” and the value of threat pattern and trend information to bank compliance efforts, and the AMLA’s expansion of the U.S.… Continue Reading
anti-money laundering
FinCEN issues assessment on possible “no-action” letters for industry
As required by the Anti-Money Laundering Act (“AML Act”), the Financial Crimes Enforcement Network (“FinCEN”) issued on June 30, 2021 its 14-page assessment regarding the feasibility of FinCEN issuing so-called “no-action” letters to financial institutions (the “Assessment”). FinCEN issued this Assessment on the same day that it issued the first government-wide list of national priorities for anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”), as we have blogged. … Continue Reading
FinCEN identifies AML/CFT “priorities” for financial institutions
As required by the Anti-Money Laundering Act (“AML Act”), the Financial Crimes Enforcement Network (“FinCEN”) issued on June 30, 2021 the first government-wide list of priorities for anti-money laundering and countering the financing of terrorism (“AML/CFT”) (the “Priorities”). The Priorities purport to identify and describe the most significant AML/CFT threats facing the United States. … Continue Reading
This week’s podcast: Federal banking regulators and FinCEN issue new statements on Bank Secrecy Act/Anti-Money Laundering enforcement: a look at highlights
Topics discussed include how the banking regulators and FinCEN will approach the decision whether to take enforcement action against a financial institution (including what BSA/AML program failures typically would (or would not) result in cease and desist orders), how the regulators’ statement differs from 2007 guidance, how the enforcement statements relate to recent updates to the BSA/AML examination manual, suggested practices for reducing compliance risk for institutions and individuals, and the Presidential election’s potential impact on BSA/AML enforcement.… Continue Reading
This week’s podcast: anti-money laundering and Bank Secrecy Act challenges
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 risk.… Continue Reading