Gregory Marshall

Gregory Marshall

Bradley Arant Boult Cummings LLP

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Latest Publications


West Virginia’s Bank of Mingo Pays $4.5 Million for BSA/AML Compliance Program Deficiencies, Showing that Small and Midsize...

A series of recent federal enforcement actions targeting weaknesses in financial institutions’ Bank Secrecy Act/anti–money laundering (BSA/AML) compliance programs continued on June 15, when the Department of Justice (DOJ),...more

6/30/2015 - Anti-Money Laundering Bank Secrecy Act Banks BSA/AML Civil Monetary Penalty Compliance DOJ Enforcement Enforcement Actions FDIC FinCEN

Dealing with high-risk clients and final advice for maintaining an effective AML compliance program

Dealing with high-risk clients in an era of enhanced AML enforcement - To identify and trace criminal activity, federal law enforcement relies on the mandatory filing of suspicious activity reports (SARs) by financial...more

4/23/2015 - BSA/AML Chief Compliance Officers Compliance Enforcement Financial Institutions FinCEN Money Services Business SAR

PayPal’s Settlement with OFAC Demonstrates Importance of Effective Sanctions Compliance Programs for Financial Institutions

On March 25, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a settlement with PayPal, Inc., the money services business, to resolve apparent violations of multiple U.S. economic...more

4/10/2015 - Chief Compliance Officers Compliance Financial Institutions OFAC PayPal Sanctions SDN List Settlement

Avoiding personal liability amidst heightened AML enforcement

In February 2014, the Financial Industry Regulation Authority (FINRA), the self-regulatory body for the U.S. securities industry, suspended a former global anti-money laundering compliance officer at Brown Brothers Harriman &...more

3/5/2015 - Anti-Money Laundering Bank Secrecy Act Chief Compliance Officers Corporate Culture Enforcement Actions FINRA Personal Liability

Heightened Enforcement Efforts Focus on Financial Institutions’ ‘Culture of Compliance’

The first of a three-part series on the new landscape of anti-money laundering enforcement - During hearings conducted in 2012 by the U.S. Senate’s Permanent Subcommittee on Investigations, Senator Tom Coburn commented...more

2/2/2015 - Anti-Money Laundering Banking Sector BSA/AML Chief Compliance Officers Compliance Corporate Culture Enforcement Enforcement Actions Ethics OCC

Fifth Circuit’s Ruling on Anti-Kickback Act May Generate More Lawsuits against Federal Contractors

In United States v. Kellogg Brown & Root, Inc., No. 12-40447 (5th Cir. July 19, 2013) (“KBR”), the U.S. Court of Appeals for the Fifth Circuit decided questions of first impression concerning the federal Anti-Kickback Act...more

7/29/2013 - Anti-Kickback Statute Contractors False Claims Act (FCA) Qui Tam Reporting Requirements Subcontractors Vicarious Liability

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