All Customer Due Diligence articles
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PremiumChapter 4: Investigations into misconduct: What banks can do
Both JPMorgan Chase and Deutsche Bank retained their respective Jeffrey Epstein relationships for too long. Yet, there is a case to be made for why exiting a high-risk relationship too soon can become an inverse form of recklessness.
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PremiumChapter 3: Egregious failures: Customer due diligence and transaction monitoring
Why did JPMorgan Chase retain Jeffrey Epstein for more than a dozen years? How did the relationship persist despite glaring red flags? The “why” is straightforward; the “how” is more complicated.
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PremiumChapter 1: Compliance v. complicity: The ‘underbelly’ of bank culture
Why were decisions made the way they were at the banks that serviced Jeffrey Epstein? Evidence points to a cultural tension: a tug-of-war between the allure of profit and the drag of compliance, with the former having all the pulling power.
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PremiumCommon sanctions compliance trip points from 2023 enforcement cases
Penalties against companies including British American Tobacco, Wells Fargo, and Microsoft demonstrate the multiple ways in which businesses can run afoul of U.S. sanctions—an area receiving increased scrutiny by regulators.
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News BriefWebull fined $3M for failing to properly supervise automated trading system
The Financial Industry Regulatory Authority fined broker-dealer Webull Financial $3 million for alleged failures related to customer due diligence and processing and reporting of customer complaints.
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News BriefCoinbase to pay $100M after NYDFS probe into compliance lapses
Cryptocurrency exchange Coinbase agreed to pay $100 million as part of a settlement with the New York State Department of Financial Services for compliance failures that opened the door for criminals to carry out illegal activity through the platform.
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ArticleMishcon de Reya fined $316K for AML failings
The Solicitors Regulation Authority, the regulatory body for solicitors in England and Wales, announced British law firm Mishcon de Reya has agreed to pay a financial penalty of £232,500 (U.S. $316,000) for AML compliance violations.
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ArticleBanking regs reemphasize rules for monitoring accounts of foreign officials
Five federal regulatory agencies issued a reminder to banks and financial institutions that they should continually monitor risks associated with the accounts of foreign officials.
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ArticleUnderstanding the why in CDD
Compliance practitioners might know how to undertake customer due diligence, but may never ask themselves why and might have limited knowledge of other anti-money laundering areas.
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ArticleFive ‘essential components’ of a sanctions compliance program
Chief compliance officers got some much-needed guidance on how to build a well-crafted sanctions compliance program thanks to the recent OFAC framework.