ANALYSIS: Federal Agencies Announce BSA/AML Enforcement Approach

The FinCEN Files leak in September has drawn attention to money laundering and the potential for large fines, massive reputational damage, and possibly even criminal liability for Bank Secrecy Act/anti-money laundering (BSA/AML) compliance failures. The aftermath of this scandal may further complicate the already complex field of BSA/AML compliance and enforcement, which involves a variety of U.S. and foreign regulatory agencies and has seen a dramatic increase in AML-related fines globally—from $4.27 billion in 2018 to $8 billion in 2019, according to one source. Nevertheless, media and political reaction to the FinCEN Files says less about the actual conduct of ...