On May 8, FINRA announced that it fined three firms a combined $900,000 and suspended four executives for allegedly failing to establish and implement adequate anti-money laundering programs. ...more
There are many unique challenges to managing an AML compliance program. Depending on the size of the bank or financial institution, each presents a different constellation of compliance factors....more
On April 4, the Federal Reserve Board released a March 25, 2013 written agreement between the Federal Reserve Board, the New York Department of Financial Services, and a German bank and its U.S. branch regarding certain...more
Last year was the year of Bank Secrecy, sanctions and anti-Money Laundering enforcement. The HSBC settlement sparked significant controversy over the claim by the Justice Department that HSBC and other banks are “too big to...more
In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - MISCELLANY - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - SECURITIES - CREDIT CARDS - PAYMENTS -...more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) has published its list and discussion of examination priorities for the investment management industry in 2013, which includes both market-wide initiatives...more
In This Issue: - FCPA Due Diligence is Critical to Avoid Successor Liability in Cross-Border Transactions - China’s Merger Control Rules...more
In This Issue: *RMBS Litigation - Assured Wins $90 Million in Damages in RMBS Breach of Contract Trial - DOJ Brings Civil Fraud Action Against S&P - S&P Seeks Declaration That Credit Ratings Are Immune From...more
On February 13, 2013, the Government of Canada published in the Canada Gazette certain amendments to the Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (the Regulations). These amendments will come...more
Financial businesses operating in the European Union will need to consider implementing stricter anti-money-laundering and anti-terrorism-financing controls or face a potential fine of up to 10 percent of their annual...more
Overview: On January 11, 2013, the Financial Industry Regulated Authority (FINRA) issued its 2013 Annual Regulatory and Examination Priorities Letter (Priorities Letter). This letter is issued annually to highlight new...more
On January 14, the Federal Reserve Board and the OCC issued two consent orders against a large international bank and its trust company over alleged deficiencies in its Bank Secrecy Act and Anti-Money Laundering (BSA/AML)...more
In This Issue: - FEDERAL ISSUES - STATE ISSUES - COURTS - FIRM NEWS - FIRM PUBLICATIONS - MORTGAGES - BANKING - CONSUMER FINANCE - E-COMMERCE - PRIVACY/DATA SECURITY - PAYMENTS -...more
The Securities and Exchange Commission has extended a no-action letter dated February 12, 2004 (the 2004 Letter) from the Securities Industry Financial Markets Association (SIFMA) that permits broker-dealers, subject to...more
I recently wrote about banks behaving badly. Currently, Exhibit A in that list is HSBC. In December, 2012, the UK banking giant HSBC agreed to pay a fine of $1.92 billion for its transgressions involving money laundering....more
I always like to make predictions at the beginning of each year. My track record is plus and minus – sometimes on target, sometimes off-target. The biggest story in the last five years has been the rise of FCPA...more
The end of the year was very tough for global banks. For months significant enforcement actions were expected in the ongoing LIBOR manipulation probe and anti-money laundering and sanctions violations probes....more
Today the Mayans predicted the world would end. I must say that I find the Mayans had a complete lack of courtesy, indeed if not foresight, as they did not identify the time the world would end and further did not specify if...more
Following on the heels of the $15 million settlement against First Bank of Delaware for significant Bank Secrecy Act/Anti-Money Laundering violations (as we reported on here), the Treasury Department and three federal...more
HSBC Holdings, London, and two of its U.S. subsidiaries have been ordered to pay a record $1.92 billion in fines and penalties for anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) violations....more
On November 19, FinCEN and the FDIC announced that a state bank agreed to pay a $15 million civil money penalty to resolve the bank’s “history of noncompliance” with Bank Secrecy Act (BSA) and anti-money laundering (AML)...more
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