Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Navigating Bank-Fintech Partnerships: Avoiding Common Pitfalls — The Consumer Finance Podcast
Episode 302 -- Matt Stankiewicz on DOJ's Massive Criminal Settlement with Cryptocurrency Exchange Binance and its CEO Changpeng Zhao
Practical Lessons Learned Regarding the Bank Secrecy Act and Anti-Money Laundering for Financial Institutions - The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: A Look at the Treasury Department’s April 2023 Report on Decentralized Finance or “DeFi”
A Discussion with Nacha on Proposed Rulemaking Regarding Fraud - Payments Pros: The Payments Law Podcast
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
Credit Eco To Go Podcast: “You are either in front of the dragon, or behind the dragon”
The New BSA Whistleblower Law: What You Need to Know
FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs
The US Department of Justice (DOJ) has announced that Wall Street Exchange (WSE), a Dubai-based money exchange service provider, entered into a non-prosecution agreement (NPA) and agreed to pay more than $9.2 million to...more
How does a respected financial institution turn into a criminal operation? In this episode of Corruption, Crime, and Compliance, host Michael Volkov dives into the record-breaking $3 billion settlement between TD Bank and the...more
Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more
TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more
We continue our exploration of the resolution of the AML/BSA enforcement action involving TD Bank US (the Bank), which is wholly owned by TD Bank Group, a publicly traded (NYSE: TD) international banking and financial...more
In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more
The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement. Last week, Lisa Monaco, DOJ’s...more
Federal prosecutors enjoy flipping through the United States Criminal Code, 18 U.S.C. §§ 1 et seq., to pick out tools to charge defendants. Over the last ten years, DOJ’s reliance on criminal charges in FCPA cases has...more
The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals. ...more
The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements. There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will...more
Larry Dean Harmon, the founder and operator of Helix, a darknet-based cryptocurrency “mixer” or “tumbler,” recently admitted that Helix partnered with darknet marketplaces to provide bitcoin money laundering services for...more
On May 25, 2021, the U.S. Department of Justice (“DOJ”) unsealed an indictment charging two Austrian citizens, Peter Weinzierl (“Weinzierl”) and Alexander Waldstein (“Waldstein”), for their roles in a scheme to launder...more
It would be the height of folly to claim that a single theme dominates the AML Act of 2020 (Act). The new law, enacted on January 1 of this year, is an extraordinarily wide-ranging and long overdue reform of the Bank Secrecy...more
On April 9, 2021, U.S. federal regulators issued an Interagency Statement addressing the application of existing model risk management guidance (MRMG) to systems or models used by banks to comply with Bank Secrecy Act (BSA)...more
On January 1, 2021, Congress enacted a broad range of anti-money laundering (“AML”) reforms within the Anti-Money Laundering Act of 2020 (the “AML Act”), as part of the National Defense Authorization Act for Fiscal Year 2021...more
On January 1, 2021, Congress enacted the Anti-Money Laundering Act of 2020 (the “Act”). As part of the National Defense Authorization Act for Fiscal Year 2021, the Act creates a broad range of new anti-money laundering...more
On October 8, 2020, the U.S. Attorney General’s Cyber-Digital Task Force released its Cryptocurrency Enforcement Framework. The Framework makes clear that, in addition to prosecuting bad actors who use cryptocurrency to...more
Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town. The Commodity Futures Trading Commission recently finished its fiscal year with...more
Building off a 2018 alert outlining cyber threats generally, and following the federal indictment for money laundering of the founders of the offshore cryptocurrency exchange BitMEX, on Oct. 8, 2020, the U.S. Department of...more
Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more
The Internal Revenue Manual defines fraud as a “deception by misrepresentation of material facts or silence when good faith requires expression, which results in material damage to one who relies on it and has the right to...more
I. Background - Sweden’s financial supervisory authority (“SFSA”) recently fined Swedbank AB a record 4 billion Swedish kronor (approximately $386 million) for deficiencies in its anti-money laundering (“AML”) processes...more
On March 4, 2020, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) assessed a civil monetary penalty of $450,000 against Michael LaFontaine, the former Chief Operational Risk Officer and...more
Compliance professionals face extraordinary risks – not just for the enterprise but personal risks. CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more
First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more