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AML due diligence for non-financial institutions: the next big thing in compliance?

Tom Fox | August 8, 2016

The scandal surrounding the Malaysian sovereign wealth fund, 1MDB, took an ominous turn last week when it was announced by the state of New York’s Department of Financial Services (DFS) that it wanted information from Goldman Sachs Group Inc. about the due diligence it may or may not have performed when it underwrote three bond sales for 1MDB in 2012 and 2013. This comes on the heels of a Wall Street Journal report that both the U.S. Department of Justice and Securities and Exchange Commission subpoenaed Goldman Sachs for documents related to the bank’s dealings with the Malaysian sovereign wealth fund.

This new request from the DFS also pointed to a specific PowerPoint presentation made by Goldman Sachs about the last of these three bonds deals. In a series of forfeiture lawsuits filed in July, Justice Department representatives alleged that...

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