Tagged: Bank Secrecy Act

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion settlement with TD Bank companies to resolve systemic and pervasive Bank Secrecy Act (“BSA”) and money laundering violations. In addition to the financial settlement, TD Bank US Holding Company (TDBUSH) (together with TDBNA,...

Congress Extends Sanctions Statute of Limitations And Addresses Other National Security Issues

On April 24, 2024, President Biden signed into law a sweeping national security legislative package that included the 21st Century Peace Through Strength Act, which includes measures to promote sanctions and export controls enforcement and focuses on China trade. The Act: The Act amends the statute of limitations for International Emergency Economic Powers Act (IEEPA) and the Trading with the Enemy Act (TWEA) to ten...

Binance Intentionally Avoided Compliance with U.S. Laws Under CEO Changpeng Zhao (II of III)

Matt Stankiewicz, Partner at The Volkov Law Group, continues his series of posts breaking down Binance’s recent criminal settlement. Matt can be reached at [email protected]. Binance’s settlement with the DOJ represents one of the largest criminal corporate enforcement actions ever.  A review of the facts reveals that the penalty is likely warranted, as the misconduct was driven from the very top.  Binance’s founder and CEO,...

FinCEN Settles with USAA Federal Savings Bank for $140 Million for Willful AML Violations

FinCEN enforcement actions for anti-money laundering violations are often interesting because of the scope of violations and the large penalties imposed.  For most financial institutions, CCOs read these enforcement actions with an eye to distinguishing their own AML programs from the target involved in the enforcement action.  I would urge some caution here – it is easy to breathe a sigh of relief and whisper...

Bank Secrecy Act Compliance During the COVID-19 Crisis

Elizabeth Slim, Senior Consultant at The Volkov Law Group, joins us for a posting on AML and BSA compliance during the current pandemic crisis. Elizabeth can be reached at [email protected]. The COVID-19 outbreak has affected all of us and we now face the new normal of self-quarantine and social distancing.  As Anti-Money Laundering (AML) professionals, we are still required to ensure that financial institutions maintain...

US Brings First Criminal AML Case Against Broker-Dealer

In a stark message, Justice Department prosecutors have brought the first criminal case for anti-money laundering violations against a broker-dealer.  Central States Capital Markets, LLC (Central States) agreed to pay a $400,000 penalty and entered into a deferred prosecution agreement (DPA) with the US Attorney’s Office for the Southern District of New York for violating the bank Secrecy Act. As set forth in the court...

Regulators Slap Banks, MSBs and Card Club with AML Violation Penalties

Financial institutions face enormous pressures with respect to anti-money laundering compliance.  These burdens are about to grow with implementation of customer due diligence rules.  In 2017, federal and state regulators stepped up AML enforcement.  Here is a quick rundown of some of the enforcement actions: Citibank paid a $70 million penalty  to the Office of the Comptroller of the Currency (here) for violating its 2012...

Rolling the Dice: Casinos, FinCEN and AML Compliance

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML compliance. In March 2015, FinCEN imposed a $10 million penalty on Trump Taj Mahal in Atlantic City, New Jersey, for violations of the Bank Secrecy Act (BSA). In addition to this hefty...