The second of a three-part series on the new landscape of
anti-money laundering enforcement.
In February 2014, the Financial Industry Regulation Authority
(FINRA), the self-regulatory body for the U.S. securities industry,
suspended a former global anti-money laundering compliance officer
at Brown Brothers Harriman & Co. and assessed a record $8
million fine against the firm for its inadequate Bank Secrecy Act
(BSA)/anti-money laundering (AML) program and lack of oversight
related to suspicious penny stock transactions. The former
compliance officer personally paid $25,000 under the settlement he
and Brown Brothers Harriman entered with FINRA.
And in December 2014, the U.S. Attorney's Office for the
Southern District of New York filed a civil enforcement action
against a former chief compliance officer for MoneyGram to enforce
a $1 million penalty assessed by the U.S. Treasury Department's
Financial Crimes Enforcement Network (FinCEN). FinCEN based its
assessment
