New Patterns In Anti-Money Laundering Enforcement

By Ann Sultan and William Barry (June 21, 2019, 2:21 PM EDT) -- Recent anti-money laundering enforcement actions demonstrate a clear pattern: They focus on programmatic compliance deficiencies rather than particular transactions and hold financial institutions accountable for the quality of their performance rather than the comprehensiveness of their policies, procedures and controls.  

Enforcement agencies have recommitted to the strategy of punishing perceived shortcomings related to anti-money laundering and Bank Secrecy Act compliance programs. Recent enforcement actions, including a deferred prosecution agreement extension of MoneyGram International Inc.[1] (and accompanying $125 million forfeiture), a consent order with Capital One Financial Corp.[2] (and $100 million civil penalty), and a settlement with Morgan Stanley[3] (including a...

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