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Active U.S. enforcement of anti-money laundering rules continues unabated

Alexander Bussey
Todd Fishman
Eugene Ingoglia

In January 2020, the U.S. Department of the Treasury issued its National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy). This document details the key priorities of the U.S. government regarding the enforcement of the Bank Secrecy Act (BSA) and its broader agenda on efforts related to anti-money laundering and the combating the financing of terrorism (AML/CFT). Marking the 50th anniversary of the BSA, the U.S. Treasury described the 2020 Strategy as identifying key threats, vulnerabilities, and priorities for disrupting and preventing illicit finance activities within and transiting the U.S. financial system, and providing a roadmap to modernize the AML/CFT regime.

The 2020 Strategy follows a year when in 2019 global enforcers imposed more than USD8 billion in anti-money laundering fines. This figure doubles the amount of penalties meted out in 2018, which approached USD4.27 billion. U.S. enforcement agencies and regulators were the most active, handing out 25 penalties totalling USD2.29 billion.

Of the world’s top 50 banks, 12 were hit with fines in 2019. Four months into 2020, this trend has continued. In March 2020, Swedbank AB was fined approximately USD400 million (4bn Swedish krona) for serious deficiencies in its anti-money laundering controls and for withholding documents from Swedish and Estonian regulators and is reportedly under investigation by U.S. enforcement agencies for the same concerns. U.S. financial regulators continue to focus on anti-money laundering enforcement, with the release of guidance and strategy documents. Most recently, in April 2020, the Federal Financial Institutions Examination Council (FFIEC) published a manual for AML examinations. In parallel to the broader strategy efforts, there have been a number of recent developments across the anti-money laundering enforcement spectrum.

Read the full article on the Allen & Overy website.

The article originally appeared in the New York Law Journal on June 3, 2020.

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