Global banks are caught in US prosecutor’s cross hairs. Not only do they have to worry about basic AML compliance and enforcement, they now have major risks in sanctions compliance. For some inexplicable reasons, global...more
The penalties for compliance missteps have never been higher — particularly in the international regulatory context. As the record-setting penalties against BNP Paribas (nearly $9 billion in penalties for violations of...more
Marshall Miller, the Justice Department’s principal Deputy Assistant Attorney General for the Criminal Division, has been heating up the compliance conference circuit in recent weeks. On September 17th, it was the Global...more
BNP Paribas’ recent settlement of nearly $9 billion for violating US Sanctions against Sudan, Iran and other countries is another important achievement for the US Attorney’s Office in the Southern District of New York and the...more
With all the attention to Anti-Money Laundering and Bank Secrecy Act enforcement, I thought it would be a good time to review some basic AML ethics and compliance principles....more