ANALYSIS: Capital One Case Teaches Old and New AML Lessons

The Capital One anti-money laundering (AML) enforcement action that concluded in January does for AML enforcement actions what Martin Scorsese’s “The Irishman” did for gangster movies: cover most of its field’s major story lines of the past and present in a massive production packed with familiar names.

With one of the country’s best-known banks receiving a $390 million penalty for AML failures in 2008–2014 that involved old-fashioned check cashing—and even featuring the Genovese crime family in a prominent role—the Capital One enforcement action is a blockbuster with rather old-school marquee features. At the same time, it is clearly forward-looking, citing ...