Call 855-808-4530 or email [email protected] to receive your discount on a new subscription.
The onslaught of civil and criminal enforcement actions against financial institutions for violating anti-money laundering and counter-terrorist financing (AML/CTF) laws has continued its brisk pace in the past few months, with enforcement of the AML provisions of the Bank Secrecy Act (BSA) and the sanctions regulations administered by the Office of Foreign Assets Control (OFAC) showing no signs of slowing down. From the recent convictions of a major French bank for conspiring to violate OFAC sanctions, to the deferred prosecution agreement with one of the largest U.S.-based banks for substantive BSA violations in connection with the Bernie Madoff fraud, money laundering and sanctions violations are clearly at the front of the government's collective mind.
In that vein, the Treasury Department's Financial Crimes Enforcement Network (FinCEN), which implements the BSA, recently and pointedly reminded U.S. financial institutions that fulfilling their AML compliance obligations is not just about policies, procedures, and compliance personnel, but implicates the very culture of an organization. In a regulatory advisory issued on Aug. 11, 2014, FinCEN sets forth “general lessons” gleaned from its enforcement of the BSA, and flatly states that “a financial institution with a poor culture of compliance is likely to have shortcomings in its BSA/AML models.” FinCEN Advisory FIN-2014-A007 (Aug. 11, 2014) (the “Advisory”).
A Culture of Compliance
ENJOY UNLIMITED ACCESS TO THE SINGLE SOURCE OF OBJECTIVE LEGAL ANALYSIS, PRACTICAL INSIGHTS, AND NEWS IN ENTERTAINMENT LAW.
Already a have an account? Sign In Now Log In Now
For enterprise-wide or corporate acess, please contact Customer Service at [email protected] or 877-256-2473
Defining commercial real estate asset class is essentially a property explaining how it identifies — not necessarily what its original intention was or what others think it ought to be. This article discusses, from a general issue-spot and contextual analysis perspective, how lawyers ought to think about specialized leasing formats and the regulatory backdrops that may inform what the documentation needs to contain for compliance purposes.
As courts and discovery experts debate whether hyperlinked content should be treated the same as traditional attachments, legal practitioners are grappling with the technical and legal complexities of collecting, analyzing and reviewing these documents in real-world cases.
How to Convey Your Merits In a Way That Earns Trust, Clients and Distinctions Just as no two individuals have the exact same face, no two lawyers practice in their respective fields or serve clients in the exact same way. Think of this as a "Unique Value Proposition." Internal consideration about what you uniquely bring to your clients, colleagues, firm and industry can provide untold benefits for your law practice.
The ever-evolving digital marketing landscape, coupled with the industry-wide adoption of programmatic advertising, poses a significant threat to the effectiveness and integrity of digital advertising campaigns. This article explores various risks to digital advertising from pixel stuffing and ad stacking to domain spoofing and bots. It will also explore what should be done to ensure ad fraud protection and improve effectiveness.
This article offers practical insights and best practices to navigate the path from roadmap to rainmaking, ensuring your business development efforts are not just sporadic bursts of activity, but an integrated part of your daily success.