Payment Law Advisor Legal Commentary and Resources for the Payment Industry

Tag Archives: Bank Secrecy Act

Lessons from Recent BSA/AML Enforcement Actions

Posted in Financial Services Litigation and Enforcement, Resource Database
On February 14, 2019, DWT FinTech co-chair Andy Lorentz gave a presentation on lessons learned from recent BSA/AML enforcement actions–a continued area of emphasis in a de-regulatory climate–to the Innovative Payment Alliance Financial Crimes Task Force. To view the presentation materials, please click here.… Read the rest

NYDFS Issues Regulation Addressing Anti-Money Laundering Transaction Monitoring and Filtering Requirements

Posted in Regulatory and Compliance
On June 30, 2016, the New York Department of Financial Services (NYDFS) issued a final regulation obliging regulated institutions to meet enhanced requirements for transaction monitoring and filtering programs aimed at preventing Bank Secrecy Act (BSA)/anti-money laundering (AML) violations and transactions with sanctioned entities (the “Fin… Read the rest

The OCC’s Increasing Focus on BSA-AML Compliance

Posted in Financial Services Litigation and Enforcement
In a speech last week to the Institute of International Bankers, Comptroller of the Currency Thomas J. Curry focused extensively on Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. Combined with the recent suggestion by Benjamin Lawsky, the Superintendent of New York’s Financial Services Department (DFS), that New York may begin requ… Read the rest

Operation Chokepoint and the Brave New World of Criminal Liability

Posted in Financial Services Litigation and Enforcement
The U.S. Department of Justice and banking regulators have stepped up the pace of criminal, civil and administrative actions against banks, payment processors, money transmitters, and other financial institutions, for violations of the Bank Secrecy Act, including through a DOJ initiative known as “Operation Chokepoint.” Criminal charges for f… Read the rest

Regulatory Action Against First Bank of Delaware Reinforces BSA and AML Concerns with Third-Party Relationships

Posted in Financial Services Litigation and Enforcement, Regulatory and Compliance
Earlier this month, First Bank of Delaware[FN1] was subjected to concurrent $15 million penalties by the Federal Deposit Insurance Corporation (FDIC) and the Financial Crimes Enforcement Network (FinCEN), along with a $15 million settlement with the Department of Justice (DOJ). The fines and penalties were in settlement of alleged violations of the B… Read the rest