A recent decision from a federal district court and a proposed regulation from the New York State Department of Financial Services provide even more reason for compliance officers at financial institutions to install robust anti-money laundering compliance programs.
Under the district court decision and proposed regulation, chief compliance officers would be personally subject to both civil and criminal liability if their institution’s anti-money laundering compliance programs are incapable of detecting and stopping illicit transactions.
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‘Enforcement 40’ for 2020
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