A recent
Reed Smith Client Alert discusses a June 2015 speech
by Stephanie Brooker, Associate Director for Enforcement at the
Financial Crimes Enforcement Network ("FinCEN"). Although
Ms. Brooker's comments were specifically directed at the casino
and card club industries, she discussed six "core
principles" that have and will continue to guide FinCEN's
BSA/AML enforcement activities against all financial institutions,
including banks and mortgage lenders. In particular, the alert
discusses FinCEN's focus on transparency, supervisory goodwill,
recidivism, targeting individual directors, officers, and other
employees of regulated entities, developing a remedial framework to
correct prior deficiencies, and accountability. As to this last
point, the alert discusses the extent to which FinCEN – and
other regulators (e.g., the OCC) – have required respondents
to actually admit liability for the charged violations, rather than
merely "neither admit nor deny" as has been
