Chapter 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.
Case study: ‘The Banks Behind the Epstein Enterprise’
This Compliance Week case study offers a deep dive into the anti-money laundering compliance failures—and alleged complicity—of JPMorgan Chase and Deutsche Bank, the two banks that enabled the Jeffrey Epstein enterprise to flourish for decades.
SFO launches probe into collapsed Carlauren Group
The U.K. Serious Fraud Office announced two raids and three arrests coinciding with the launch of an investigation into collapsed property developer Carlauren Group.
SFO director support for whistleblower incentives enough to drive change?
When Nick Ephgrave of the Serious Fraud Office said in his maiden speech he favored paying whistleblowers in exchange for information, he might not have been fully aware of the implications, according to legal experts.
DOJ eyeing more FCPA cases with whistleblower program
The Department of Justice anticipates its upcoming whistleblower reward program will help the agency increase its pipeline of cases involving apparent violations of the Foreign Corrupt Practices Act, said Acting Assistant Attorney General Nicole Argentieri.
CW National 2024 Q&A: JBS CECO on compliance post-settlement
Michael Koenig, global chief ethics and compliance officer at JBS Foods, previews his session on rebuilding the compliance department following settlements with the Department of Justice and Securities and Exchange Commission at CW’s National Conference in Washington, D.C.
DOJ on sprint toward pilot whistleblower reward program
Deputy Attorney General Lisa Monaco said the Department of Justice will look to fill gaps in its whistleblower procedures with the launch of a 90-day sprint toward a DOJ-led pilot whistleblower reward program.
Ericsson promotes investigations head to CCO
Ericsson shook up its reporting structure with the promotion of Head of Corporate and Government Investigations Rebecca Rohr to chief compliance officer.
FCA warns CEOs over firm AML failings
The U.K. Financial Conduct Authority warned the chief executive officers of approximately 1,000 financial institutions it supervises regarding common failures in anti-money laundering procedures it observed during recent assessments.
Judge’s ruling calls FinCEN beneficial ownership registry into question
A federal court judge in Alabama ruled the Corporate Transparency Act was beyond Congress’s power, potentially throwing the effectiveness of the Financial Crimes Enforcement Network beneficial ownership information registry into doubt.
Metropolitan Commercial Bank adds risk chief, AML officer
Metropolitan Commercial Bank announced the appointments of a chief risk officer and Bank Secrecy Act/anti-money laundering officer to bolster its reporting lines following a $30 million enforcement action from federal and state authorities last year.
CW National 2024 preview: Former Albemarle CCO on FCPA case lessons
Andrew McBride, former chief risk and compliance officer at chemical company Albemarle Corp., joins the Compliance Week podcast with Aaron Nicodemus to preview his session at CW’s National Conference in Washington, D.C.
Gunvor to pay $661M to settle FCPA violations in Ecuador
Swiss-based oil trader Gunvor will pay more than $661 million as part of a plea agreement with the Department of Justice to resolve violations of the Foreign Corrupt Practices Act involving a long-running scheme to bribe officials in Ecuador to secure oil contracts.
Swedbank says Estonia money laundering probe closed
The Estonian branch of Swedbank is no longer under investigation regarding suspected money laundering and other criminal activities.
Green Dot estimates up to $50M in liabilities over proposed Fed order
Financial technology firm Green Dot Corp. estimated a pending consent order with the Federal Reserve Board will require a payment of between $20 million to $50 million.
NYDFS fines Gemini $37M over compliance failures
The New York State Department of Financial Services fined cryptocurrency exchange Gemini Trust Company $37 million over alleged compliance failures related to lapses in safety and soundness.
FCA vows transparency, faster case outcomes in new enforcement strategy
The U.K. Financial Conduct Authority will rein in its enforcement focus and commit to providing more updates on its ongoing investigations as part of a revamped strategy designed to quicken the pace and increase the deterrent impact of its cases.
FinCEN head touts compliance through enforcement approach
Andrea Gacki, head of the Financial Crimes Enforcement Network, said recent enforcement actions by the agency have addressed significant gaps in the U.S. anti-money laundering/countering the financing of terrorism regime and exposed specific risk factors, trends, and typologies.
New European AML agency to be based in Germany
The European Union’s recently approved Anti-Money Laundering Authority will be based in Frankfurt, Germany, and begin operations in 2025.
FATF adds Kenya, Namibia to AML/CFT watchlist; UAE, Uganda removed
Kenya was one of two African countries included in the Financial Action Task Force’s latest update to its list of jurisdictions under increased monitoring for money laundering and terrorist financing, while the United Arab Emirates was among four countries removed.
Experts: No easy fix for U.K. senior manager accountability shortcomings
Legal experts generally agree the U.K.’s record for prosecuting board-level executives for financial and economic crime could be better. But some believe there is a problem criticizing poor enforcement when the legislation in place has its own shortcomings.
Lloyds discloses FCA probe into AML controls
Lloyds is the latest U.K. financial institution being probed by the Financial Conduct Authority regarding its anti-money laundering control framework.
Ten things I’m excited for at CW National 2024
A new month and a new venue but a lot of the same you love about Compliance Week’s National Conference. CW Editor in Chief Kyle Brasseur shares what he’s looking forward to most at the 2024 edition of the annual event.
Barclays says FCA probe into AML controls closed
Barclays Bank disclosed an investigation by the U.K. Financial Conduct Authority into the bank’s anti-money laundering controls has closed without a penalty.
SFO raids kick off probe into collapsed Signature Group
The U.K. Serious Fraud Office carried out several residential raids as it announced the launch of a criminal investigation into collapsed property investment firm Signature Group.
The path to DOJ cooperation credit: Analyzing recent FCPA cases
Recent enforcement actions offer guidance on what the Department of Justice considers to be an “imminent threat” of disclosure or government action, what it means by “prompt” disclosure, and how a company can earn credit for revealing all relevant facts.
LRN survey: Compliance programs shifting focus from bribery, corruption
Many ethics and compliance programs have refocused their efforts away from bribery and corruption and onto data security and privacy, complex government regulations, artificial intelligence security, and other contemporary challenges, a survey from LRN found.
FinCEN head: Agency seeking to educate, not punish, BOI reporters
The Financial Crimes Enforcement Network will focus its attention regarding compliance with its new beneficial ownership reporting requirements on education and outreach during the first year of implementation, although “willful violations” will still merit punishment.
Ex-Sterling Bank GC cited by OCC over BSA-related failures
The Office of the Comptroller of the Currency issued a cease-and-desist order against the former general counsel at Sterling Bank and Trust for not ensuring the institution’s Bank Secrecy Act compliance and failing to timely file suspicious activity reports.
DAG Monaco: AI to be top DOJ enforcement priority
The Department of Justice will seek stiffer penalties in cases where the threat of misconduct was greater because of misuse of artificial intelligence, according to Deputy Attorney General Lisa Monaco.
FinCEN: BSA data shows spike in crypto-financed human trafficking
Bank Secrecy Act reporting data disclosed by the Financial Crimes Enforcement Network revealed a significant spike in the use of cryptocurrency to finance human trafficking.
New SFO director vows quicker cases, stumps for whistleblower payouts
“Under my leadership, the SFO will be bolder, more pragmatic, more proactive,” said Nick Ephgrave in his first public speech as head of the U.K. Serious Fraud Office.
FinCEN to propose applying BSA requirements to investment advisers
The Financial Crimes Enforcement Network will propose categorizing investment advisers as financial institutions that must comply with the Bank Secrecy Act, including having an anti-money laundering program.
Insurance broker Gallagher off hook in DOJ FCPA probe
Arthur J. Gallagher disclosed the Department of Justice ended an investigation into the insurance broker’s business in Ecuador for potential violations of the Foreign Corrupt Practices Act.
Anti-fraud groups praise FinCEN AML proposal for real estate transactions
The Financial Crimes Enforcement Network issued a notice of proposed rulemaking that would require the handlers of all-cash residential real estate transactions in all U.S. cities and counties to disclose the beneficial owners.
Raytheon parent discloses indications of improper payments in Middle East
RTX Corp., parent company of aerospace and defense giant Raytheon, disclosed an internal investigation launched into potential improper payments in connection with contracts in the Middle East found indications of misconduct.
Paytm denies money laundering claims amid regulatory scrutiny
The Reserve Bank of India ordered a halt to many banking activities of digital payments provider Paytm while the regulator investigates “persistent noncompliances and continued material supervisory concerns.”
ACAMS survey: Budget cuts, criminal tech innovation top 2024 threats
Nearly 800 financial crime professionals said the biggest threats to the effectiveness of their anti-money laundering programs are budget cuts and their inability to keep pace with more aggressive and innovative uses of technology by criminals to commit fraud.
City National Bank ordered to pay $65M over deficient risk, internal controls
The Office of the Comptroller of the Currency levied a $65 million civil penalty against Los Angeles-based City National Bank over alleged risk management and internal control failures.
Calavo Growers discloses potential FCPA issues
Multinational produce and agriculture company Calavo Growers disclosed in an annual filing an investigation into its Mexico operations found potential issues under the Foreign Corrupt Practices Act.
Compliance officer BSA case a cautionary tale for small banks
A New York-based Bank Secrecy Act compliance officer facilitated more than $1 billion in high-risk international financial business through an “unsophisticated” institution, according to the Department of Justice and the Financial Crimes Enforcement Network.
TD Bank reportedly facing fine for faulty AML controls
The Financial Transactions and Reports Analysis Centre of Canada is reportedly preparing to issue its largest fine to date against TD Bank for faulty anti-money laundering controls.
Treasury cites Iraqi bank, owner over terrorist financing concerns
Al-Huda Bank faces severance from the U.S. financial system for being a conduit of terrorist financing, according to the Financial Crimes Enforcement Network, while its owner, Hamad al-Moussawi, was sanctioned by the Office of Foreign Assets Control.
The pros and cons of generative AI in AML compliance
Generative artificial intelligence providers often promote their technologies as revolutionary tools that can enhance anti-money laundering processes. But the issues and shortcomings associated with the technologies must also be acknowledged.
MGM Grand, Cosmopolitan fined $7.5M total over BSA violations
Two Las Vegas casinos agreed to pay penalties of nearly $7.5 million as part of separate non-prosecution agreements with the Department of Justice addressing violations of the Bank Secrecy Act over alleged anti-money laundering compliance failings.
FCPA violations in China: Lessons learned from 2023 cases
Enforcement actions regarding alleged violations of the Foreign Corrupt Practices Act at 3M, Albemarle, Clear Channel Outdoor, and Royal Philips each had China touchpoints. Experts assess third-party risk management lessons learned from each case.
ICBC fined $32M by NYDFS, Fed over compliance lapses
The Industrial and Commercial Bank of China and its New York branch agreed to pay $32.4 million in penalties levied by two regulators for failing to address compliance failures and for the unauthorized disclosure of confidential supervisory information to an overseas regulator.
EU nearing tighter AML rules for crypto, luxury traders
The European Union moved closer to finalizing rules that would expand current anti-money laundering and customer due diligence obligations to new sectors, in addition to granting greater powers to national financial intelligence units.
AML pros say tech, not hiring, will keep them ahead of financial crime
A survey of financial crime professionals found that while three of every four companies added more anti-money laundering employees in 2023, nearly all respondents said growing their department’s headcount alone won’t keep up with emerging risks.
AMLA impact dependent on national collaboration
The impact of the Anti-Money Laundering Authority to improve the coordination and success of AML activities will be largely indirect, depending on its influence over European national governments continuing to supervise most EU financial services firms.