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Articles by Jessica C. Watt
UK Regulator Fines Commerzbank London £37.8 Million for AML Violations
FCA Applies Penalty Formulas, Including Thirty Percent Reduction for Early Agreement by Bank U.K. Enforcement System Provides Contrast to More Open-Ended U.S. System On June 17, 2020, the Financial Conduct Authority (“FCA”), the non-governmental financial regulator in the United Kingdom, issued a Final Notice to Commerzbank London (the “Bank”), a branch of the large German business bank, assessing it £37.8 million for systemic failures to establish and effectively maintain an anti-money...
UK Regulator Fines Commerzbank London £37.8 Million for AML Violations
FCA Applies Penalty Formulas, Including Thirty Percent Reduction for Early Agreement by Bank U.K. Enforcement System Provides Contrast to More Open-Ended U.S. System On June 17, 2020, the Financial Conduct Authority (“FCA”), the non-governmental financial regulator in the United Kingdom, issued a Final Notice to Commerzbank London (the “Bank”), a branch of the large German business bank, assessing it £37.8 million for systemic failures to establish and effectively maintain an anti-money...
FFIEC BSA/AML Examination Manual Updates Reveal Exam Process and Expectations
Examiners Should Focus on Risk, Not Technical Perfection On April 15, 2020, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to the Bank Secretary Act/Anti-Money Laundering (“BSA/AML”) examination manual (the “Manual”).
Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions
Report Focuses on Anonymity, Real Estate Transactions and Complicit Lawyers Report Also Signals Upcoming AML Regulation for Certain Niche Institutions Second Post in a Two-Post Series In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities.
Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key Threats
First in a Two-Post Series The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”). This document sets forth the key priorities of the U.S. government regarding enforcement of the Bank Secretary Act (“BSA”), and the furthering of the government’s Anti-Money-Laundering (“AML”) and Combating the Financing of Terrorism (“CFT”) goals in general.
Money Laundering Watch: 2019 In Review
Happy New Year! And, happy birthday to Money Laundering Watch, which is entering its third year. Let’s look back. 2019 has been yet another busy year in the world of money laundering and BSA/AML.
Two Former Venezuelan Officials and Energy Executives Indicted as DOJ Continues to Use Money Laundering Charges to Combat Foreign Corruption
Last week, a grand jury in the Southern District of Florida indicted two former Venezuelan officials, charging them with seven counts of money laundering and one count of money-laundering conspiracy. The charges relate to bribes and kickbacks provided to the officials who headed the country’s energy department and state-owned electricity company, Corporacion Electrica Nacional, S.A. (“Corpoelec”).
Former Danske Bank CEO Charged by Danish Prosecutors in Connection with Massive Money Laundering Scandal
Authorities Begin to Focus on Individual Responsibility This week, Danish prosecutors charged Thomas Borgen, the former chief executive officer of Danske Bank, for his involvement in the money laundering scandal arising out of Danske Bank’s Estonian branch, involving an astonishing 200 billion euros ($224 billion) in alleged suspicious transactions.
The House Financial Services Committee Releases Proposed Legislation to Codify BSA/AML Reform Initiatives
Bill Would Create BSA Whistleblower Program First Post in a Three-Post Series Last week, the House Financial Services Committee released three proposed bills to codify many of the reform ideas that have arisen in an ongoing conversation among financial agencies, law enforcement, financial institutions, and commentators regarding the Bank Secretary Act (“BSA”) and Anti-Money-Laundering (“AML”) and Combating the Financing of Terrorism (“CFT”) laws.
FinCEN Director's Remarks Highlight AML Regulatory Reform Efforts
Director Blanco Emphasizes BSA Resource Sharing, Technological Innovation, and Collaboration Between Public and Private Sectors The Financial Crimes Enforcement Network (FinCEN) released prepared remarks delivered by FinCEN director, Kenneth A. Blanco, at the Securities Industry and Financial Markets Association (SIFMA) Anti-Money Laundering (AML) & Financial Crimes Conference on February 4, 2019.
Danske Bank CEO Resigns on Heels of Report Detailing an Astounding $234 Billion in Suspicious Transactions in Money Laundering Scandal
Estonian “Non-Resident Portfolio” Produces Colossal Money Laundering Scandal This week Danske Bank released a report detailing the results of its much anticipated internal investigation into allegations of money laundering perpetrated in its Estonian branch. The results of the investigation dwarfed even the boldest predictions.
Former Guinean Minister of Mines Sentenced to Seven Years in Prison for Laundering $8.5 Million in Bribes Paid by Chinese Companies in Exchange for Mining Rights
U.S. Money Laundering Charges Stemmed from Foreign Bribes to Foreign Official by Foreign Companies On August 25, a U.S. District Court Judge for the Southern District of New York sentenced former Guinea Minister of Mines and Geology, Mahmoud Thiam, to seven years in prison, followed by three years of supervised probations, for laundering $8.5 million bribes paid to him by China Sonangol International Ltd. and China International Fun, SA (CIF).
Damming the Funding to North Korea: Anticipatory Seizure Warrants as a Tool to Enforce Sanctions and Thwart Money Laundering Transfers
Two days after North Korea’s successful long-range ballistic missile test, the U.S. District Court for the District of Columbia unsealed a memorandum opinion which granted the Department of Justice “damming” warrants to seize all funds in bank accounts belonging to five Chinese companies which allegedly were used to hide transactions with North Korea using U.S. currency in violation of U.S. sanctions and money laundering laws.
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