Categories
FCPA Compliance Report

The FinCen Papers


In this podcast, I am joined by Piero Molinario, Senior Managing Director, Head of Financial Crimes Risk and Compliance for EMEA for K2 Intelligence FIN and Joanne Taylor, Managing Director, K2 Intelligence FIN who works with clients investigations and financial crime compliance, including fraud risk management, anti-bribery and corruption, regulatory enforcement, and fraud investigations. Both are located in London. We take a deep dive into the FinCen Papers.
Some of the highlights include:

  1. What are the FinCen Papers?
  1. What is the significance of their release?
  1. Does this release hurt financial institutions?
  1. Does it hurt the regulators?
  1. Do the FinCEN Papers show there is more work to be done?
  1. Are there any positive takeaways from the release of the FinCEN papers?

For more information on K2 Intelligence FIN, check out their website here.
For additional reading see the white paper, The FinCEN Files Impatiently Bypasses Government Entities Responsible for Acting on SARs Filings.
See also the following policy, Policy Alert: ICIJ Leaked SAR Investigation Highlights Opportunity for BSA/AML Reform, 25 September 2020

Categories
This Week in FCPA

Episode 223 – the FinCen Papers edition


As the ICIJ releases some 2100 SARs from FinCen detailing over $2 trillion in illegal banking activity, the fires in California, Oregon and Washington finally abate. Tom and Jay are back to look at top compliance articles and stories which caught their eye this week.

  1. The FinCen Papers. Banks and SARs. (NYT) HSBC allowed Ponzi scheme. (BBC) Cache of FinCen docs made public. (BBC) Aaron Nicodemus says it puts compliance in a bad light in Compliance Week (Sub Req’d). Martin Woods on the breach of trust in Compliance Week (Sub Req’d). Jaclyn Jaeger says look at the banks, In Compliance Week (Sub req’d). Matt Kelly weighs in on Radical Compliance.
  2. More data analytics tools for compliance. Dylan Tokar in the WSJ Risk and Compliance Journal.
  3. What makes a ‘Great Woman in Compliance’. Mary Shirley reports on her journey as co-host of #GWIC in CCI.
  4. What does doing more with less mean for compliance? Matthew McFillin and Amanda Rigby in the FCPA Blog.
  5. What are the 7 sins of ESG Management? FTI in the Harvard Law School Forum on Corporate Governance.
  6. The largest AML case in Hong Kong history. Jon Rausch in Dipping Through Geometries.
  7. Oil trader cops to FCPA violation. Harry Cassin breaks the story on the FCPA Blog
  8. Why the Board needs a separate Compliance Committee. Mike Volkov in Corruption Crime and Compliance.
  9. This month on The Compliance Life, I am joined by DeAnna Nwankwo. In this week’s Part 3, DeAnna talks about building trust as a CCO.
  10. On the Compliance Podcast Network, on 31 Days to a More Effective Compliance Program, this month focuses on internal controls. This week saw the following offerings: Monday– Objective I; Tuesday– Objective II;Wednesday– Objective III; Thursday– Objective IV; and Friday– Objective 5. Note 31 Days to a More Effective Compliance Program now has its own iTunes channel. If you want to binge out and listen to only these episodes, click here.
  11. Join Jay and Tom at Converge20. Convercent’s top compliance conference is going virtual this year. Check at the agenda and register here.
  12. Join K2 Intelligence FIN, on September 30 for a webinar with the AIBACP, “Strategies for Surviving an Offsite Regulatory Examination,” featuring Koby Bambilia, K2 FIN Managing Director, and a panel of experts, from banks to regulators. Registration and information here.

Tom Fox is the Compliance Evangelist and can be reached at tfox@tfoxlaw.com. Jay Rosen is Mr. Monitor and can be reached at jrosen@affiliatedmonitors.com.

Categories
Compliance Into the Weeds

Compliance into the Weeds: When is Diversity Training Anti-American Propaganda/the FinCen Files?


Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. In this episode Matt and Tom go into the weeds to look at the recent initiative of the Department of Education to go after Princeton University for diversity training which Trump says is “Anti-American propaganda” and the release of the FinCen papers. Some of the issues we consider are:

  • What is the Trump Administration up to?
  • Will white nationalism be the order of the day if Trump wins?
  • Why does impact compliance professionals?
  • What are the FinCen papers?
  • Why was their release so devastating to the Administration?

Resources
See Matt’s blog posts on Radical Compliance
Boom: The FinCen Files are Here
Trump Administration Targets Princeton for Diversity