News & Analysis as of

Personal Liability FinCEN

King & Spalding

Personal Liability Exposure for Bank Executives and Compliance Officers

King & Spalding on

On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its assessment of a civil monetary penalty totaling $450,000 against Michael LaFontaine, a former Chief Operational...more

Mintz - Securities & Capital Markets...

The New York City Bar Association Goes to Bat for Compliance Officers

The New York City Bar Association Compliance Committee (“Committee”) recently issued a report encouraging financial regulators to provide a clear framework for when compliance officers may be held personally liable for the...more

WilmerHale

AML Litigation and Individual Liability: FinCEN's Landmark Haider Case Moves Forward

WilmerHale on

A federal district court in Minnesota recently held that the Bank Secrecy Act (BSA) permits the Financial Crimes Enforcement Network (FinCEN) to bring suit against individuals for willfully violating the BSA's AML program...more

Manatt, Phelps & Phillips, LLP

“Culture of Compliance” Urged by FinCEN

Following months of rumors that the Financial Crimes Enforcement Network (FinCEN) is preparing to impose personal liability on officers, directors and employees for shortcomings in their financial institutions’ Bank Secrecy...more

Morrison & Foerster LLP

Individual Liability: What’s Behind The Headlines?

It’s been open season on financial institutions since the 2008-2009 financial crisis (“Financial Crisis”). State and federal prosecutors and regulators are competing with each other for press coverage of their latest consent...more

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