FinCEN Ponders No-Action Letters

FinCEN

The chief anti-money laundering agency in the United States is asking for public comment on the idea of developing a no-action letter process, in case any of your AML compliance professionals want to voice your thoughts about this potential new avenue for regulatory guidance.  No-action letters are already used by several other regulatory agencies, and…

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Capital One Whacked on AML Failures

Talk about mistakes that come back to haunt you: Capital One just agreed to pay a $390 million penalty for anti-money laundering compliance failures in a check-cashing unit the bank hasn’t even owned for seven years.  The settlement was announced by FinCEN last Friday. The 22-page statement of facts is a tale of poor risk…

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FinCEN Gives Guidance, Says Little

FinCEN

Anti-money laundering regulators gave fresh guidance Monday about what financial firms should do for adequate customer due diligence — guidance that was, alas, light on specific steps to take. Instead, compliance officers have a three-page document best described as “Do what you think is best, based upon risk.” The guidance comes from FinCEN, the Financial…

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Another Great Example of Poor Compliance Culture

I just love the casino business. Every thinker and observer of corporate compliance issues should. Really, where else can you find such a perfect blend of internal control and corporate culture concerns, plus all those whacky casino names? The enforcement examples you find here always straddle hard-edged financial controls and business practices that make you…

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