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Money Laundering Compliance Examinations
For money-laundering compliance officers, a classic Bob Dylan song offers a word of sound advice: “You better start swimming or you'll sink like a stone, for the times they are a-changin'.” Or, as acting Chief Counsel for the Comptroller of the Currency Dan Stipano told Florida bankers on Feb. 10, “In every war we have ever fought, bankers have been on the front lines. While most banks have been willing partners … what was good enough in the past may not be good enough now. The stakes are much, much higher than ever before and a 'business as usual' approach is not going to be sufficient.” Banks that fail to head these warnings will face onerous regulatory orders, fines, and possible criminal investigation.
The biggest change that financial institutions face is the new, expanded-scope anti-money laundering (AML) regulatory examination and the proliferation of Written Agreements, Memoranda of Understanding, or Cease and Desist Orders issued by bank regulatory agencies should the financial institution be found to be deficient. An analysis of recent regulatory orders including, among others, AmSouth, ABN AMRO, Standard Chartered, Hudson United Bank, and City National Bank, demonstrates that the regulators are focused on multiple issues.
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