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

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

Five U.S. regulatory agencies—the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”)—released on October 3, 2018 an Interagency Statement on Sharing Bank Secrecy Act Resources (“Statement”).