Miscellaneous
Topics include how banking regulators and FinCEN will approach the decision whether to bring an enforcement action (including what BSA/AML program failures typically would (or would not) result in cease and desist orders), how the regulators’ statement differs from 2007 guidance, how the statements relate to recent updates to the BSA/AML examination manual, suggested practices for reducing compliance risk for institutions and individuals, and the Presidential election’s potential impact on enforcement.