2018 Mid-Year Anti-Money Laundering Review and Outlook
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- Personal Liability: Regulators continue their efforts to hold compliance officers, senior executives and board members personally liable for compliance failures.
- Focus on Obstruction: U.S. prosecutors and regulators are focusing on misrepresentations and obstruction by financial institution managers during routine AML exams.
- Agency Coordination: Agencies are working together to avoid the disproportionate penalties that can result when different agencies with overlapping jurisdictions each levy their own penalties for the same or similar AML violations.