This the feature article from our Issue #2, 2017 FIRMA FORUM Newsletter. Members can view the entire issue, and past issues, in our archive
Banks and other financial institutions entered 2017 facing an increasingly daunting framework of anti-money laundering (AML) laws and regulations. During the past several years, regulatory agencies have been aggressively stepping up their enforcement actions, and they’ve levied huge fines for compliance failures.
For instance, the New York State Department of Financial Services1 (NYDFS) and the UK Financial Conduct Authority2 recently issued penalties of more than $600 million for AML failings at Deutsche Bank from 2011 to 2015 in connection with securities trades originating in Russia. In addition, the Financial Industry Regulatory Authority’s 2017 Regulatory and Examination Priorities Letter3 indicated that AML will remain a focus-especially in areas where the agency has observed shortcomings. The letter expressed specific concern about lapses in data integrity and inadequate surveillance systems that have caused gaps in firms’ automated trading and money movement surveillance systems.