Anti-Money Laundering Enforcement: The Rise of Individual Liability for Compliance Professionals
Author: Sharon Cohen Levin.; Elizabeth J. Hogan.; Tamar Kaplan-Marans.
Source: Volume 31, Number 04, Summer 2018 , pp.5-14(10)
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Abstract:
Individual anti-money laundering (AML) compliance officers appear to be increasingly threatened with liability for failure to detect and prevent wrongdoing at their financial institutions. After setting out the key elements of the current regime of AML regulation, the authors describe the current trend as it has emerged in public statements from regulators, recent AML enforcement actions, and regulatory developments. They conclude with program suggestions to reduce risk for compliance professionals and their employers. *This article is adapted, with updates by the authors, from The Review of Securities & Commodities Regulation, © RSCR Publications LLC, and is available for download for Journal of Taxation & Regulation of Financial Institutions subscribers only; no pay-per-article option is available.Keywords: compliance, AML, U.S. Department of Treasury v. Haider, compliance officers, individual liability
Affiliations:
1: WilmerHale; 2: WilmerHale; 3: WilmerHale.