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Bank Secrecy Act and Anti-Money Laundering Programs Continue to Result in Significant Penalties



byStephen F. Donahoe
Kilpatrick Townsend & Stockton LLP - Washington Office

Erich M. Hellmold
Kilpatrick Townsend & Stockton LLP - Washington Office

Aaron M. Kaslow
Kilpatrick Townsend & Stockton LLP - Washington Office

Michael A. Mancusi
Kilpatrick Townsend & Stockton LLP - Washington Office

Kevin M. Toomey
Kilpatrick Townsend & Stockton LLP - Washington Office

February 20, 2014

Previously published on February 19, 2014

Bank Secrecy Act (“BSA”) compliance, and in particular anti-money laundering (“AML”) controls, remains a focus of regulators as evidenced by record fines levied in recent weeks. On February 7, 2014, the Financial Industry Regulatory Authority, Inc. (“FINRA”) suspended a former AML compliance officer at Brown Brothers Harriman (“BBH”) and assessed a record $8 million fine against the firm for its inadequate AML program and lack of oversight.


 

The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.
 

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Stephen F. Donahoe
Erich M. Hellmold
Aaron M. Kaslow
Michael A. Mancusi
Kevin M. Toomey
 
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