Last year, financial regulators around the world imposed more than $2 billion in fines related to anti-money laundering (“AML”) compliance failures. With AML enforcement shifting into a higher gear, financial institutions need a comprehensive picture of regulatory priorities so they can effectively build their compliance functions.
To assist financial institutions in this effort, the Debevoise Banking Group has compiled the 2017 Anti-Money Laundering Year in Review and 2018 Outlook, summarizing 19 AML enforcement actions initiated or concluded in 2017. The report identifies three key AML enforcement trends:
- An increased inclination by regulators to hold compliance officers and other employees personally liable for compliance failures.
- The continued assertion by New York State’s Department of Financial Services of a prominent role in AML enforcement.
- Notable AML enforcement activity outside of the United States.
The Anti-Money Laundering Year in Review and 2018 Outlook concludes with a convenient chart of recent AML enforcement actions.
Our significant experience in handling our clients’ most complex enforcement and regulatory matters led Law360 to name us its 2018 Banking Group of the Year.
We hope that you find the 2017 Anti-Money Laundering Year in Review and 2018 Outlook to be a helpful reference guide and we look forward to discussing AML developments and best practices at your convenience. On behalf of all of our colleagues in the Banking Group and Debevoise more broadly we thank you for your continued trust and confidence in us.
Matthew L. Biben
Gregory J. Lyons