Dick Cassin, writing in his FCPA Blog , has
consistently raised the issue of Anti-Money Laundering (AML) in the wider
battle against bribery and corruption. He set out some of his thoughts in a
post entitled " 9/11 and the
FCPA ". He also speaks regularly about AML laws as one component...
an article in the Tuesday Wall
Street Journal (WSJ), entitled " More
foreign banks probed for sanctions violations ", Brett Wolf reported
that the New York County District Attorney's Office will shortly announce
additional enforcement actions against banks for sanctions violations...
Anti-money laundering has been a key compliance and at
times enforcement issue for years. This is particularly true since the passage
of the PATRIOT Act in 2001. David Blass, Chief Counsel, Division of Trading and
Markets, recently provided insight on past compliance and enforcement efforts
Financial Action Task Force (FATF) is an inter-governmental body
established in 1989 by the Ministers of its Member jurisdictions. Its mandate
is to set standards and to promote effective implementation of legal,
regulatory and operational measures for combating money laundering, terrorist financing...
While many companies which operate under anti-bribery laws such as the UK Bribery Act or anti-corruption laws such as the US Foreign Corrupt Practices Act (FCPA), have compliance programs in place to review business relationships, I have found that one of the areas which most non-banking companies do...