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ARTICLE · 25 MARCH 2014

An Overview Of AML For EMDs

Miller Thomson
Miller Thomson
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Miller Thomson

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The headlines are eye-catching and the amounts involved mind-boggling.

CanadaCorporate/Commercial Law
Susan Han
Susan Han
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The headlines are eye-catching and the amounts involved mind-boggling. "HSBC to pay $1.9 Billion in U.S. Anti-Money-Laundering Case....," "JP Morgan Chase Agrees to $2.6 Billion..." in a settlement Manhattan U.S. Attorney Preet Bharara promised was "...not the last big money-laundering" case his office would bring. And across the pond, Standard Bank was fined £7.6 Million for failure to enforce its AML rules. Most recently, BNP Paribas set aside $1.1 Billion to pay potential penalties for violations of anti-money-laundering laws and economic sanctions.

The typical EMD does not handle physical cash, and many do not control or have custody over client assets. That is no reason to be complacent about AML compliance. EMDs are Securities Dealers under AML legislation, and are subject to an extensive and wide-ranging set of obligations.

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