New Multi-Front Enforcement Action Emphasizes Key AML Compliance Requirements

Shinhan Bank America ("Shinhan"), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network ("FinCEN"), Federal Deposit Insurance Corporation ("FDIC"), and the New York Department of Financial Services ("NYDFS"). These concurrent actions resulted in a total of $25 million in civil penalties for failing to develop and implement an effective AML program in accordance with the Bank Secrecy Act ("BSA") and New York law, based on ongoing, unremedied compliance failures that the agencies allege were apparent dating back to at least 2015.

The consent orders provide valuable insight into current areas of regulatory oversight and focus, applicable not just to traditional financial institutions, but to Fintechs and virtual asset companies as well. In fact, although it took more than six years of alleged failures to meet AML requirements outlined in formal agreements between Shinhan and