Anti-Money Laundering Compliance — FinCEN Ups The Ante
Law360, New York ( August 25, 2014, 10:19 AM EDT) -- Following several notable criminal and civil enforcement actions against financial institutions,[1] the Financial Crimes Enforcement Network recently issued a regulatory advisory to emphasize certain critical elements of an effective Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance program.[2] The advisory focuses on effective steps that financial institutions and their leadership should take to "improve and strengthen organizational compliance with BSA/AML obligations."[3] The enhanced focus on BSA/AML compliance by both FinCEN and each of the federal banking agencies (FBAs)[4] dictates that all financial institutions — from multinational bank-holding companies to regional and community banks to nonbank financial services companies — should review and update, as appropriate, their BSA/AML compliance programs and policies to ensure they conform to the heightened regulatory expectations detailed in the advisory....
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