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Heightened AML Risks for Entities Doing Business with Shell Companies  


Author:  Ryan Fayhee.; Samuel Salyer.


Source: Volume 35, Number 09, September 2019 , pp.117-121(5)




Review of Banking & Financial Services

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Abstract: 

Recent changes in US regulations now require a broad range of financial institutions to identify and in certain cases to verify, the ultimate beneficial owners of their customers, and to use that information in their AML compliance programs. The authors discuss these changes in the US, and similar heightened requirements in the EU and the British Virgin Islands. They close with a discussion of recent illustrative enforcement actions and the lessons they provide for financial institutions and others.

Keywords: FinCEN, Assessment of Civil Money Penalty in the Matter of UBS Financial Services Inc, Number 2018-03

Affiliations:  1: Hughes Hubbard and Reed; 2: Hughes Hubbard.

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