Tagged: Money Service Businesses

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...

The Banking Stepchild: Money Service Businesses

Sometimes risk analysis can result in paralysis. Finding your risk tolerance and applying it to specific situations requires a nuanced approach. I am always wary of anyone who tells me categorical rules – e.g. we do not do business in Russia because it is too risky. In this era of oversimplification, such statements border on intellectual dishonesty. A careful approach to risk analysis always involves...