A recent Department of Treasuryโ€™s Financial Crimes Enforcement Network (FinCen) enforcement action raised the eyebrows of many compliance professionals, as Thomas Haider, Moneygramโ€™s CCO, during a period of sustained money-laundering violations by the company, was individually prosecuted in the first anti-money laundering (AML) enforcement action for the failure to implement a compliance program. In a civil settlement, Haidar agreed to a fine of $250,000 and to not work in the industry for three years. The question for CCOs is: Does this portend a shift in enforcement strategies?

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...