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
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
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
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
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
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