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Ask not for whom the bell tolls, it may toll for you next: intensified anti‐money‐laundering enforcement transforms the regulatory landscape

Betty Santangelo (Partner at Schulte Roth & Zabel LLP, New York, New York, USA.)
Margaret A. Jacobs (Associate with the firm.)

Journal of Investment Compliance

ISSN: 1528-5812

Article publication date: 1 January 2005

2213

Abstract

Purpose

Discusses the most significant criminal prosecutions and regulatory actions in response to recent anti‐money laundering compliance lapses and the resulting concern in the financial community.

Design/methodology/approach

Reviews earlier criminal enforcement actions; the recent prosecution of Riggs Bank; non‐criminal regulatory enforcement actions toward Banco de Chile, Korea Exchange Bank, Arab Bank, and Gulf Corporation; additional consent orders and supervisory agreements requiring enhancement of PATRIOT Act and Bank Secrecy Act compliance systems at more than 20 banks; broker‐dealer actions; and other actions.

Findings

Concludes that both law enforcement and regulators have embraced stricter anti‐money‐laundering enforcement standards despite some criticism from the financial industry, and that recent criminal enforcement actions bear careful analysis by the financial community; predicts that regulators and law enforcement officials will broaden their scope from banking institutions to include broker‐dealers and other non‐bank institutions as well; and recommends that all financial institutions devote greater resources to establish effective anti‐money‐laundering policies and procedures, particularly in the areas of due diligence for high‐risk customers and suspicious activity reporting (SAR).

Originality/value

A detailed review of recent anti‐money‐laundering violations and enforcement actions along with practical recommendations for financial institutions by two expert compliance lawyers with a specialty in anti‐money‐laundering.

Keywords

Citation

Santangelo, B. and Jacobs, M.A. (2005), "Ask not for whom the bell tolls, it may toll for you next: intensified anti‐money‐laundering enforcement transforms the regulatory landscape", Journal of Investment Compliance, Vol. 6 No. 1, pp. 4-15. https://doi.org/10.1108/15285810510634650

Publisher

:

Emerald Group Publishing Limited

Copyright © 2005, Emerald Group Publishing Limited

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