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ANALYSIS: Federal Agencies Announce BSA/AML Enforcement Approach

Sept. 29, 2020, 7:51 PM

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 ...