Beschreibung:
PurposeDiscusses the most significant criminal prosecutions and regulatory actions in response to recent anti‐money laundering compliance lapses and the resulting concern in the financial community.Design/methodology/approachReviews earlier criminal enforcement actions; the recent prosecution of Riggs Bank; non‐criminal regulatory enforcement actions toward Banco de Chile, Korea Exchange Bank, Arab Bank, and Gulf Corporation; additional consent orders and supervisory agreements requiring enhancement of PATRIOT Act and Bank Secrecy Act compliance systems at more than 20 banks; broker‐dealer actions; and other actions.FindingsConcludes that both law enforcement and regulators have embraced stricter anti‐money‐laundering enforcement standards despite some criticism from the financial industry, and that recent criminal enforcement actions bear careful analysis by the financial community; predicts that regulators and law enforcement officials will broaden their scope from banking institutions to include broker‐dealers and other non‐bank institutions as well; and recommends that all financial institutions devote greater resources to establish effective anti‐money‐laundering policies and procedures, particularly in the areas of due diligence for high‐risk customers and suspicious activity reporting (SAR).Originality/valueA detailed review of recent anti‐money‐laundering violations and enforcement actions along with practical recommendations for financial institutions by two expert compliance lawyers with a specialty in anti‐money‐laundering.