Financial Services


Compliance lessons from Goldman Sachs’ $2.9B 1MDB settlement


Jaclyn Jaeger explores compliance takeaways from Goldman Sachs’ $2.9 billion global bribery settlement for its role in the 1MDB scandal.

Dark money

‘FinCEN Files’ reaction poll: Corporate culture blocks AML compliance


In the aftermath of the “FinCEN Files” leak, financial industry practitioners polled by Fenergo say changing the system needs to start within their own institutions.

Cost rising

Study: Financial crime compliance costs top $42B in U.S./Canada


A new study of financial crime compliance costs found spending by American and Canadian financial institutions is up sharply in 2020, driven in part by the coronavirus pandemic.

Trump vs. Biden

What would a Democratic regulatory agenda look like under Biden?


Democratic presidential nominee Joe Biden is no lock to win the presidency on Nov. 3. But it’s worth examining what compliance-related regulatory policies he’d support if he wins.


Is human trafficking financial services’ blind spot?

2020-10-20T16:24:00+01:00By Jake Plenderleith, International Compliance Association

A new report from BAE Systems demonstrates just how far we have to go in the fight against money laundering, particularly when it comes to human trafficking.

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USAA $85M fine for compliance failures lacks justification


The OCC’s recent $85 million penalty assessed against USAA for compliance risk management failures leaves too many questions unanswered for a fine that size, writes Jaclyn Jaeger.


Wells Fargo gives us another reason to doubt their culture comeback


While Wells Fargo ends up with yet another “Failed It” this week, we salute the principled Deutsche Bank whistleblower whose refusal to accept “dirty money” cost him everything.


Deutsche Bank fined $15.9M for lag in reporting suspicious transactions


A German public prosecutor levied a €13.5 million (U.S. $15.9 million) fine against Deutsche Bank for failing to report over 600 suspicious transactions in a timely manner but dropped a wider investigation related to the Danske Bank money laundering scandal.

Danske Bank

How Danske is cleaning up after a €200B money laundering scandal


It is not clear what action Danske Bank will take on the back of its investigation into Europe’s biggest-ever money laundering scandal, but it is a safe bet to think further improving compliance will be on the list.


Back to the drawing board on transaction monitoring


In the wake of the “FinCEN Files” leaks, Martin Woods examines whether monitoring text rather than numbers in transactions could serve as a solution to our greater anti-money laundering woes.

Morgan Stanley

OCC fines Morgan Stanley $60M for data inventory risk failures


Morgan Stanley has agreed to pay $60 million as part of a settlement with the OCC for failing to adequately protect customer data when the bank decommissioned two U.S.-based wealth management data centers.


U.S. agencies get nod for using data, smart incentives in enforcement

2020-10-08T17:17:00+01:00By Compliance Week

Both the CFTC and CFPB “Nailed It” this week while corporate heavyweight General Electric found itself in more trouble.


Citigroup fined $400M for compliance, risk management failures


Federal banking regulators fined Citigroup $400 million for failing to address “significant” risk and compliance failures.


FINMA orders Banca Credinvest to improve AML measures


The Swiss Financial Market Supervisory Authority found Banca Credinvest “seriously breached” anti-money laundering regulations with regard to dealings with PDVSA in Venezuela.


Climate-related risk disclosures reach global boiling point


From local governments around the world to U.S. regulators to activist investors, the debate over corporate climate-related risk disclosures is approaching a boiling point.


Former hedge fund CCO fined, suspended for impeding investigation


The former CCO of a New York City investment firm who impeded a Securities and Exchange Commission investigation into her employer has been fined $25,000 and suspended from practicing before the SEC for a year.


With ‘FinCEN Files,’ don’t shoot the messenger


It’s important we understand with the “FinCEN Files” that the enemy is not a journalist, a regulator, or a banker. The enemy is the money launderer, and this is where we need to focus our thinking and resources, writes Martin Woods.

Morgan Stanley

Morgan Stanley fined $5M for short sales violations


The SEC has hit Morgan Stanley with a cease-and-desist order imposing a censure and a $5 million penalty resulting from violations of Regulation SHO, the agency’s regulations governing short sales.


Compliance failures at JPMorgan highlighted in record $920M spoofing fine


JPMorgan Chase agreed to pay more than $920 million as part of an agreement with three federal agencies to settle allegations that the firm’s traders manipulated the precious metals markets with false trades.


Citibank affiliates fined $4.5M for deleting subpoenaed audio files


Three Citibank affiliates have been collectively ordered to pay $4.5 million to settle CFTC charges regarding supervision failures that led to the deletion of subpoenaed audio files.


BoA a silver lining in damning ‘FinCEN Files’ report; Wells Fargo CEO puts foot in mouth

2020-09-25T20:27:00+01:00By Compliance Week

Bank of America gets a pat on the back for going beyond an “observe and report” approach to filing a SAR, and we learned this week that Wells Fargo’s CEO needs a little unconscious bias training.


‘FinCEN Files’ show Europe’s AML efforts maybe aren’t so world class


The damning revelations from the “FinCEN Files” leaks have once again put Europe and its supposed world-leading anti-money laundering rules under the spotlight.


Westpac set to pay record $912.6M civil penalty for AML failures


Westpac is bracing for a record AUS$1.3 billion (U.S. $912.6 million) civil penalty issued by Australia’s financial crime regulator related to a money-laundering scandal and the facilitation of child exploitation in the Philippines and Southeast Asia.

Bank confusion

‘FinCEN Files’ fallout: Where do banks go from here?


The “FinCEN Files” report raises the question: What should banks be doing to address the trillions of dollars’ worth of banking transactions that are facilitating criminal activity every year?


FinCEN leaks impart key lessons on basics of writing SARs


Martin Woods, who has analyzed many of the suspicious activity reports released as part of the “FinCEN Files,” offers best practices for compliance officers in writing SARs.

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‘FinCEN Files’ highlight bank leadership flaws, not compliance flaws


Compliance has been taking some heat in the wake of the “FinCEN Files” reports, but it’s banks’ senior leadership that failed, not the folks filing all those SARs.

Wells Fargo

Former Wells Fargo execs settle with OCC for fake account scandal roles


Three former senior executives of Wells Fargo Bank must pay a combined total of $1.675 million in civil money penalties in settlements with the OCC for their individual roles in the bank’s now-infamous fake account scandal.


FinCEN leaks damage trust between banks and regulators, but serve higher purpose


The “FinCEN Files” leaks divided opinions within the community of financial crime compliance officers. Trust has been damaged, writes Martin Woods, but these leaks could facilitate real reform.


‘FinCEN Files’ report casts compliance officers in unfair light


The BuzzFeed “FinCEN Files” investigation purportedly uncovered evidence of a catastrophic, international collapse of internal controls within the world banking system. But that argument is misleading, to the point of being disingenuous.


Visa appoints new chief compliance officer


Payment services giant Visa this month appointed Obiamaka Madubuko as its new chief compliance officer.


Swedbank being investigated for suspected market abuse


Swedbank announced the Swedish Financial Supervisory Authority has opened an investigation into the bank for potential violations of the regulation on market abuse in connection to the disclosure of suspected money laundering.

Bank fail

Recent OCC case shows widespread liability when a BSA program fails


Who faces liability when a Bank Secrecy Act program is deemed to be deficient? A series of recent enforcement actions taken by the OCC against individuals at a now-defunct New Jersey bank provides a case study.


CCO for investment firm altered docs to cover compliance failures, SEC says


A New York investment advisor and broker-dealer firm and its former chief compliance officer have been fined and censured for not fixing compliance failures identified by two federal agencies, then altering documents in an attempt to convince investigators the failures had been addressed.


Volkswagen completes monitorship; Deloitte family leave policy too good to be true?

2020-09-17T20:32:00+01:00By Compliance Week

Volkswagen gets a nod this week for successfully completing its 3-year compliance monitorship related to Dieselgate. Deloitte, on the other hand, lands on the wrong side of our list.


Assessing the fallout from coronavirus relief loan frauds


In both the U.S. and U.K., millions (perhaps billions) of dollars of coronavirus relief loans intended for small businesses is believed to have been misused. Legitimate businesses have been hurt as a result, writes Martin Woods.


A step toward managing climate risk in U.S. financial system


A nearly 200-page report on managing climate risk in the U.S. financial system is comprehensively assembled by a group spearheaded by CFTC Commissioner Rostin Behnam, but the real work comes in its implementation.


EY chairman: Auditors should work harder to find fraud


The chairman and chief executive of Big Four auditing firm EY says auditors should do more to uncover fraud while conducting external audits, a topic the industry has historically been reluctant to tackle.


Former Goldman Sachs chief risk officer leaves for BNY Mellon


BNY Mellon poached from a competitor when it announced the hiring of former Goldman Sachs Chief Risk Officer Robin Vince as vice chair and CEO of Global Market Infrastructure.


Credit to JPMorgan Chase in this week’s banking-themed naughty/nice list

2020-09-10T21:14:00+01:00By Compliance Week

JPMorgan Chase, Danske Bank, Deutsche Bank, and Bank of America all either “Nailed It” or “Failed It” this week.


Deutsche Bank Trust to pay $583K in Ukraine sanctions settlements


Deutsche Bank Trust Company Americas has reached a pair of settlements with the Office of Foreign Assets Control totaling $583,100 for apparent violations of Ukraine-related sanctions.

Wells Fargo

FINRA sanctions Wells Fargo $2M over variable annuity switches


Two Wells Fargo subsidiaries were ordered to pay more than $2 million due to supervisory failures regarding the switching of customers’ variable annuities, the Financial Industry Regulatory Authority announced.


AIG whistleblower claims in lawsuit he was fired for uncovering fraud


A former attorney for AIG has alleged in a federal whistleblower lawsuit that he was fired after he complained about fraudulent activity related to an attempt to spin off a separate legal services company.


Forget the status quo: Proactive AML is the path forward


The AML community is guilty of tolerating the failing status quo, and very few have dared to confront, challenge, and disrupt the inefficient and ineffective practices. A proactive approach could be the solution, writes Martin Woods.


Credit social media giants for prepping for election chaos

2020-09-03T18:12:00+01:00By Compliance Week

Silicon Valley’s social media heavyweights deserve a nod for “war-gaming” potential misinformation scenarios in advance of November’s elections, while McDonald’s again finds itself on our “Not Lovin’ It” list.

Credit Suisse

Credit Suisse faces FINMA enforcement in corporate espionage case


Credit Suisse is learning the hard way that spying on former colleagues is frowned upon, following announcement of an enforcement proceeding against the Zurich-based bank by the Swiss Financial Market Supervisory Authority.

California State House

With CFPB in ‘retreat,’ California eyes state consumer finance agency


California wants to create its own state consumer finance protection agency because the federal Consumer Financial Protection Bureau is in “retreat,” Democratic Gov. Gavin Newsom says.


Best practices KYC: What to do when your client is in the headlines


How do we, as AML professionals, assess negative media alerts? It should start with a conversation with the client relationship manager, but it shouldn’t end there, writes Martin Woods.


Robinhood adds two CCOs amid reported SEC probe


Online stock trading platform Robinhood last week announced the appointment of two chief compliance officers as it reportedly faces scrutiny from the SEC and FINRA regarding its March system outages.


What the Wirecard story tells us about red flags, healthy skepticism


How we came to learn about the fraud allegedly perpetrated by Wirecard offers important lessons in compliance and corporate governance, writes financial crime expert Martin Woods.


Credit to KPMG for shining a light on fraud at Wirecard

2020-08-27T15:08:00+01:00By Compliance Week

A scathing report on the extensive fraud at German payment giant Wirecard had a compliance silver lining: KPMG’s by-the-books, transparent approach to a special audit helped bring that fraud to light.