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ARTICLE · 16 SEPTEMBER 2020

New BSA/AML Enforcement And Compliance Guidance

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Several financial services regulators have recently released guidance that provides transparency to financial institutions regarding the agencies' enforcement of the Bank Secrecy Act (BSA)...

United StatesGovernment, Public Sector
Andrew E. Talbot
Andrew E. Talbot
Kevin Toomey
Kevin Toomey
Michael Mancusi
Michael Mancusi
Richard Alexander
Richard Alexander
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Several financial services regulators have recently released guidance that provides transparency to financial institutions regarding the agencies' enforcement of the Bank Secrecy Act (BSA), including examples of Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance program deficiencies that may warrant enforcement action. This guidance represents a response to calls by the banking industry for relief from BSA/AML regulatory burdens, and it brings welcomed clarity about what agencies consider when determining whether to take enforcement actions against banks and other financial institutions for perceived BSA/AML violations. The guidance and its key points are detailed below. Ultimately, these latest pronouncements by the federal banking agencies and the Financial Crimes Enforcement Network (FinCEN) confirm that regulators remain vigilant against BSA/AML violations.

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