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Compliance Kitchen

Russia and FinCEN Updates


The Kitchen heads to Russia where another foreign NGO is marked as “undesirable.”  Back in the States, FinCEN is getting ready for another ransomware themed FinCEN Exchange.

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Compliance Kitchen

FinCen Priorities


The Financial Crimes Enforcement Network (FINCEN) issued a policy on government-wide priorities (“Priorities”) for anti-money laundering (AML) and countering the financing of terrorism (CFT).  The Priorities identify and describe the most significant AML/CFT threats that the US is facing – the Kitchen is there to take a closer look at what goes into this recipe.

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Daily Compliance News

May 19, 2021 the Slow Start edition


In today’s edition of Daily Compliance News:

  • AML whistleblower program getting off the ground slowly. (WSJ)
  • Amazon under investigation by German anticompetition watchdog. (BBC)
  • $100MM stolen from Wirecard just before its collapse. (FT)
  • US accuses officials of corruption. (WaPo)
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Daily Compliance News

April 28, 2021 the Flip the Accountant edition


In today’s edition of Daily Compliance News:

  • Biden Administration to increase FinCEN budget by 50%. (DeCrypt)
  • Archegos losses over $10bn. (FT)
  • Will Trump’s accountant flip? (FT)
  • Of IPOs and customer service. (WSJ)
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Daily Compliance News

March 2, 2021, the FinCEN takes Center Stage edition


In today’s edition of Daily Compliance News:

  • Biden Administration to continue hard line on Chinese trade practices. (WSJ)
  • Two Yanks extradited to Japan. (NYT)
  • FinCEN takes center stage. (WSJ)
  • Trader Joe’s fired a whistleblower. (WaPo)
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Compliance Into the Weeds

FinCEN Enforcement Action involving Capital One

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. Today we consider the Capital One resolution of the FinCEN enforcement action. We look at the compliance program; red flags missed, and how the bank was faulted as its compliance program was found to be not effective.
Resources:
See Matt’s blog post Capital One Whacked on AML Failures
See Tom’s blog post the Capital One FinCEN Enforcement

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

FinCen DD Pronouncements-Did they Hurt More than Help?


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 two recent pronouncements by FinCen on customer and PEP due diligence. We ask the question: Is the Guidance so vague as to actually hurt the efforts of a compliance practitioner.
Resources
See Matt’s blog posts on Radical Compliance
Regulators Talk PEPs and Due Diligence
FinCen Gives Guidance, Says Little

Categories
Daily Compliance News

March 18, 2020-the Be Farewell to the Golden Boy edition


In today’s edition of Daily Compliance News:

  • Apple fined $1bn plus in Europe. (WSJ)
  • FinCen urges caution out there. (CadwaladerCabinet)
  • Worried about coronavirus? How about asbestos? (WSJ)
  • The golden boy announces he’s leaving. (Slate)