The SEC’s Division of Examinations is continuing to stress the importance of AML and BSA compliance. If you haven’t seen it, the Division issued a Risk Alert in late March highlighting AML deficiencies it identified in their reviews of broker-dealers and mutual funds. Inadequate AML… Read More »SEC Issues AML Risk Alert
The first tangible sign of FinCEN moving forward with implementation of the Anti-Money Laundering Act (AMLA) of 2020 comes just as Director Ken Blanco announces his departure to join Citi as chief compliance officer of its newly created financial crimes unit. On April 1, FinCEN… Read More »Beneficial Owner Reporting Requirements
As a longtime banker in the highly regulated financial services sector working with client onboardings, I experienced firsthand the challenges created by the existing manual, paper-intensive processes. Constantly changing guidelines meant changing client-facing documents and processes, slowing the client onboarding timeline and frustrating customers. I… Read More »A Note From Our New Chief Revenue Officer
A Michigan credit union consented to a cease-and-desist order issued by the National Credit Union Administration Board (NCUA) for AML failures related to banking marijuana regulated businesses (MRBs). The shortcomings involve the fact that the credit union lacked automated compliance and suspicious activity monitoring systems… Read More »Challenges of Banking Marijuana Regulated Businesses
A US broker-dealer was fined $450K for AML violations by FINRA because it failed to detect suspicious low-priced securities trading and failed to conduct due diligence on numerous foreign financial institution correspondent accounts. One interesting point is that, although averaging more than 40,000 low priced… Read More »Firm Fined 500K for AML Failures
The UK’s FCA brought criminal proceedings against NatWest for AML violations, which is the first criminal prosecution against a bank for violations of the UK’s Money Laundering Regulations. The case involves failure to properly monitor and scrutinize increasingly large amounts of cash deposits (in total… Read More »NatWest Charged with Criminal AML Violations
During the FATF plenary sessions in late February, the organization added the following countries to their “grey list” (i.e., those countries under increased monitoring): Burkina Faso, the Cayman Islands, Morocco and Senegal. Note also that Iceland and Mongolia, due to improvements in their AML/CFT regimes,… Read More »Updates to FATF Grey List
The Anti-Money Laundering Act of 2020, which went into effect in January 2021, is the most sweeping change to the AML regulations since the passage of the PATRIOT ACT in 2001. Check out an article we wrote about AMLA 2020, which was published in Traders Magazine.
The 2021 Report on FINRA’s Examination and Risk Monitoring Program highlights AML as one of the organization’s areas of focus. FINRA listed nine common AML-related exam findings, such as inadequate AML transaction monitoring, unclear delegation of AML responsibilities, and insufficient independent testing. FINRA also highlighted… Read More »FINRA 2021 Examination and Risk Monitoring Report
On January 19, FinCEN jointly with other banking regulators issued a FAQ document relating to the filing of Suspicious Activity Reports (SARs). The FAQs provide answers to the following questions: Can a financial institution maintain an account or customer relationship for which it has received… Read More »New Guidance on SAR Filing Requirements
