Subject to Inquiry

Subject to Inquiry

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Government Investigations and White Collar Litigation Group

Category Archives: Anti-Money Laundering

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Anti-Bribery and Corruption, Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

The Financial Services Authority continues its thematic reviews into anticorruption compliance – now it is the turn of asset managers

So far, since the Bribery Act came into force on 1st July 2011, the largest fines have been dished out by the FSA, which regulates the financial services sector in the UK, rather than by the courts… Continue Reading
Anti-Money Laundering

Integrating Anti-Money Laundering and Anti-Fraud Efforts

Recent statements from the federal government’s top anti-money laundering (AML) official make clear that the government views AML and anti-fraud as necessarily intertwined.  Banks and other financial institutions ignore this fact at their own peril.  John Byrne and Chris Swecker hit the nail on the head when they wrote earlier this year that banks should… Continue Reading
Anti-Money Laundering

Florida Court Finds Redaction Insufficient to Protect Confidentiality of SAR Investigation

A recent case in Florida provides an excellent reminder of the confidentiality restrictions that govern the release of Suspicious Activity Reports (SARs) (pdf). By way of background, the Bank Secrecy Act (BSA) prohibits banks and other financial institutions from notifying any person involved in a suspicious transaction that the transaction has been reported. When a… Continue Reading
Anti-Money Laundering, Fraud, Deception and False Claims

Anti-Money Laundering Compliance: Treasury Department Expands Information Sharing Program

On February 10, 2010, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, issued new regulations to allow foreign law enforcement agencies, as well as state and local law enforcement agencies, to obtain certain information from banks and other “financial institutions,” as that term is defined by the Bank… Continue Reading
Anti-Money Laundering, Fraud, Deception and False Claims

Anti-Money Laundering Compliance: SAR Filings Show Increases for Suspected Check Fraud

On January 22, 2010, the Financial Crimes Enforcement Network (FinCEN) reported that filings of Suspicious Activity Reports (SARs) during the first six months of 2009 for check fraud increased for all of the industries required to file SARs under the Bank Secrecy Act (BSA), as compared to the first six months of 2008. For example,… Continue Reading

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