When:  November 13, 12 Noon

Sign Up Here

Join me and Carlos Ortiz, LeClairRyan

The Department of Justice and the Treasury Department (FINCEN and OFAC) have been increasing enforcement of anti-money laundering laws. The Justice Department brought significant cases against ING Bank and other foreign banks for violating sanctions against Iran, Cuba and other countries. Now, it is focusing on a number of cases under the Bank Secrecy Act (“BSA”) which target financial institutions for weak internal control systems designed to catch potential money launderers.

The Justice Department’s aggressive approach indicates a new standard and strategy which goes beyond that normally required by bank and other financial institution regulatory agencies. The implications of this new strategy are significant and raise serious risks of enforcement actions.

At the same time, bank regulators are turning up the heat on money laundering compliance. FINCEN has proposed to require banks and other financial institutions to identify and confirm the beneficial owners of an account – an inquiry which can require layer after layer of investigation and due diligence. This controversial new regulatory requirement could have a major impact on all financial institutions.