News & Analysis as of

Corporate Compliance Officers Face Threat of Civil Monetary Penalties and Criminal Prosecution for Institutional AML Deficiencies

While financial institutions have long faced the possibility of civil monetary penalties and criminal prosecution for violations of the Bank Secrecy Act (“BSA”) and its implementing regulations, found at 31 C.F.R. Chapter X,...more

AML Compliance: The Four Pillars

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

AML Enforcement – A New Era Of Compliance

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

Senate Committee on Banking Holds Hearing on Lax Enforcement of the Bank Secrecy Act

As recently reported, the Senate Committee on Banking, Housing and Urban Affairs (information here), on March 7, 2013, held a hearing on “Patterns of Abuse: Assessing Bank Secrecy Act Compliance and Enforcement”. The...more

The HSBC AML Settlement - Lessons Learned for the AML Compliance Practitioner

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

Record Fines against HSBC for Repeated Bank Secrecy Act and OFAC Violations

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

Record $1.92 Billion in Fines and Penalties Levied against HSBC

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

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