aml

AML Programs and Recent Consent Orders: What Questions Should you be Asking?

Last year’s news headlines screamed about financial crimes: the riveting cryptocurrency saga of Sam Bankman-Fried (SBF), Binance’s landmark $4.3 billion settlement with the Department of Treasury, and Deutsche Bank’s additional fines for anti-money laundering and sanctions failings.

Other noteworthy stories entailed a parade of cybercrimes like ransomware and email scams.

For those working in the anti-money laundering sectors of financial institutions, such stories are more than a sound bite; they affect our daily work and cause us to wonder and worry about upcoming changes and whether federal examiners will adjust their approach to AML/CFT Exams.

Without a crystal ball, the best gauge of what may be coming is to monitor recent Consent Orders issued by the federal regulators and look for trends in those orders. Staying current with these trends becomes an important tool for BSA Officers, who are obligated to keep the institution’s Board of Directors apprised of developments.

TCA has analyzed eight consent orders and monetary penalties issued in 2023 by the OCC, FRB, and FDIC* that focused on BSA/AML sanctions. Here are some insights.

TCA – A Better Way!

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