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ARTICLE · 16 FEBRUARY 2017

Anti-Money Laundering Expectations In 2017

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Recent agency guidance, rulemakings, and enforcement actions—all issued prior to the change in administrations—demonstrate the financial regulatory agencies' commitment to enforcing the Bank Secrecy Act...

United StatesGovernment, Public Sector
Christopher Allen
Christopher Allen
David Freeman, Jr.
David Freeman, Jr.
Michael Mancusi
Michael Mancusi
Brian McCormally
Brian McCormally
Kevin Toomey
Kevin Toomey
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Recent agency guidance, rulemakings, and enforcement actions—all issued prior to the change in administrations—demonstrate the financial regulatory agencies' commitment to enforcing the Bank Secrecy Act and its implementing regulations (BSA), and, in particular, their willingness to hold lead compliance professionals personally accountable. Add to that the new administration's rhetoric of fighting terrorism and bolstering national security, and financial institutions should expect an upsurge of anti-money laundering (AML) supervision and enforcement in the coming years.

I. Recent Actions Imposing Personal Liability

Two recent enforcement actions against financial institutions and their AML officers support this expectation and should serve as stark warnings to individuals charged with ensuring compliance with the BSA.

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