News & Analysis as of

Policies and Procedures Money Laundering BSA/AML

Orrick, Herrington & Sutcliffe LLP

FINRA fines broker-dealer $500K for failure to file suspicious activity reports

On August 22, FINRA accepted a Letter of Acceptance, Waiver, and Consent (AWC) from a broker-dealer member firm regarding its alleged failure to establish and implement policies and procedures designed to detect suspicious...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Katten Muchin Rosenman LLP

Businesses Must Prepare For Expansive AML Reporting of Beneficial Ownership Interests

As covered in our earlier advisory, "AML Enforcement Continues to Trend in 2021," the recently passed National Defense Authorization Act for fiscal year 2021 included the Anti-Money Laundering Act of 2020 (AML Act), which...more

Foodman CPAs & Advisors

The BSA Casts A Wider Net

On  September 15, 2020,  FinCEN issued a Final Rule stating that Banks lacking a Federal Functional Regulator will be required to establish and implement AML programs including policies and procedures,  a dedicated compliance...more

Herbert Smith Freehills Kramer

OCIE Releases 2020 Examination Priorities

The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) published its 2020 Examination Priorities, an annual publication that enhances transparency and provides insights into...more

Foodman CPAs & Advisors

Who are you partnering with for your Financial Institution’s BSA/AML Independent Testing?

Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

Ballard Spahr LLP on

The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more

Bass, Berry & Sims PLC

Anti-Money Laundering Update: FinCEN Makes Small Texas Bank Pay Big Fine for Violating Bank Secrecy Act

Bass, Berry & Sims PLC on

This Post at a Glance: - FinCEN imposes $2 million penalty against community bank - Bank failed to conduct appropriate due diligence related to Mexican customer - Small banks, other financial institutions need to...more

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