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Money Laundering: A Changing Paradigm
When government officials speak, those regulated by them should listen carefully. Over the past several months there has been a slew of public pronouncements that should put financial institutions on edge. Enhanced enforcement of the Foreign Corrupt Practices Act (FCPA) is now migrating into the financial sector and linking up with anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) compliance requirements.
Item: The Financial Industry Regulatory Authority (FINRA) wrote to securities industry executives last March to “highlight new and existing areas of particular significance to FINRA's examination program for 2009,” warning them to reassess their firms' compliance and supervisory programs with special attention to AML and the FCPA. The letter concludes: “We hope that by sharing these areas of potential examination focus and other developments, your Firm will be well armed to assess your compliance operations, internal controls and supervisory systems.” http://www.finra.org/web/groups/industry/@ip/@reg/@guide/documents/industry/p118113.pdf
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