The New York DFS finalized its new AML and Sanctions screening regulations.
Interestingly, the NYDFS backed off its original proposal to require a Chief Compliance Officer to certify to a compliance “finding” that the...more
7/21/2016
/ Anti-Money Laundering ,
Banking Sector ,
Banks ,
BSA/AML ,
Certification Requirements ,
Chief Compliance Officers ,
Compliance ,
Cooperative Compliance Regime ,
Covered Entities ,
Economic Sanctions ,
NYDFS ,
Office of Foreign Assets Control (OFAC)
With the rise of OFAC Sanctions enforcement and compliance issues, companies have to devote significant resources to following changes in OFAC Sanctions. Over the last few years, the US government has significantly altered...more
7/8/2016
/ Bureau of Industry and Security (BIS) ,
Burma ,
Compliance ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Sanctions ,
Financial Institutions ,
Foreign Subsidiaries ,
General Licenses ,
Iran Sanctions ,
ITSR ,
Myanmar ,
Office of Foreign Assets Control (OFAC) ,
Parent Corporation ,
Physical Presence Test ,
Popular ,
SDN List
The resurgence in anti-money laundering enforcement in the last few years reflects the overall improvement in the banking industry and recovery from the financial collapse. Federal prosecutors and regulators have renewed...more
With the Panama Papers scandal and government promises of continued aggressive AML enforcement, financial institutions face a variety of risks that require increased vigilance and mitigation strategies....more
5/31/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Compliance ,
Financial Institutions ,
Foreign Banks ,
Foreign Corrupt Practices Act (FCPA) ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Terrorism Funding
The media loves a scandal. In the banking and compliance world, the latest scandal to hit the media was the Panama Papers. The Panama Papers is surprising in scope – Panama has become the favorite financial haven for money...more
Financial institutions have been pushing back hard on FinCEN’s proposal to require banks, investment banks and other financial institutions to identify beneficial owners of account holders. As time goes on the impact of...more
Putting aside the politics surrounding the Iran Nuclear Deal, the exchange of prisoners and other hot button political issues surrounding Implementation Day and the change in US-Iran relations, the new Iran sanctions create a...more
The Department of Treasury’s Office of Foreign Asset Control continues to ramp up sanctions enforcement. Even with the likely relaxation of the Iran and Cuba sanctions, OFAC has been continuing its aggressive enforcement...more
9/24/2015
/ Banking Sector ,
Banks ,
Civil Monetary Penalty ,
Commerzbank ,
Compliance ,
Criminal Investigations ,
Cuba ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Protection ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Hackers ,
Iran ,
Iran Sanctions ,
Office of Foreign Assets Control (OFAC) ,
Policy Violations ,
Russia ,
Sanctions ,
Schlumberger ,
U.S. Treasury ,
Ukraine
Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies.
In the end, AML compliance...more
8/13/2015
/ Anti-Money Laundering ,
Banking Sector ,
Banks ,
BSA/AML ,
Chief Compliance Officers ,
Compliance ,
Due Diligence ,
Filing Requirements ,
Financial Institutions ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Risk Assessment ,
Sanctions ,
SAR ,
Software ,
Suspicious Activity Reports (SARs)
AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of...more
I have been writing lately about the rise of OFAC sanctions enforcement. OFAC and the Justice Department have started to build a close working relationship similar to that between the SEC and the Justice Department relating...more
Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions, global financial institutions do not need...more
People are good at complaining. People often say to themselves, “Things are not going my way,” and they love to feel sorry for themselves. People who are professional victims are toxic....more
Companies are worried more and more about sanctions compliance. As the number and complexity of sanctions grow, depending on the twists and turns of our foreign policy, companies are whipsawed in the area of sanctions...more
The Department of Justice and the Treasury Department have stepped up AML/BSA and Sanctions Enforcement. With the ever-increasing expansion and modification of sanctions, risks for all businesses, not just financial...more
The Department of Justice and the Treasury Department have stepped up AML/BSA and Sanctions Enforcement. With the ever-increasing expansion and modification of sanctions, risks for all businesses, not just financial...more
I am always wary of definitive “best practices” lists. By definition, “best practices” vary depending on the size and nature of an organization in any compliance context....more
It is odd how a foreign crisis can have a dramatic impact on the world of ethics and compliance. Foreign policy headaches turn into compliance nightmares when the United States becomes embroiled in foreign events....more
4/21/2014
/ Barack Obama ,
Compliance ,
Ethics ,
Executive Orders ,
Foreign Banks ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanctions ,
SDN List ,
U.S. Treasury ,
Ukraine
AML enforcement often includes sanctions violations. The Office of Foreign Asset Control (OFAC) is responsible for regulating and enforcing the sanctions regime....more