Anti-Money Laundering

Where red flags or 'high risk factors with respect to money laundering activities' were present, the firm didn't conduct the enhanced AML due diligence it ...

The firm didn't have sufficient resources devoted to its compliance function to adequately review and address the suspicious activity identified by its surveillance systems

Deutsche Bank Securities took more than two years to file SARs where the underlying AML investigation and subsequent SAR filing were prompted by receipt of ...

SogoTrade’s independent AML auditor identified recurring weaknesses in SogoTrade’s AML program, which it repeated in each of its annual reports

The SEC cautions that SARs must contain "a clear, complete, and concise description of the activity, including what was unusual or irregular that caused suspicion"

Broker-dealers typically have trade surveillance and asset movement surveillance functions within their compliance structure

Private fund managers can read the risk alert as a warning

Here are directions to help you obtain your FinCEN ID to make it easier to comply with the Corporate Transparency Act

Consider your 'vulnerabilities' to being used for money laundering when crafting your P&Ps, including the investment products you offer, investment recommendations, distribution channels, intermediaries used ...

Be careful giving a CCO too many hats to wear. FinCEN warns 'multiple additional job duties' 'generally would not fulfill" the requirement to have an ...