Since 1996, when California became the first state to legalize marijuana (at the time, for medicinal purposes only), 28 additional states and the District of Columbia have legalized marijuana to some extent. Public support for legalization continues to rise as more and more jurisdictions loosen their marijuana laws, with 64 percent of Americans in favor
Western Union to Pay $586 Million in Restitution and Civil Penalties for AML Compliance Failure
On January 19, 2017, Western Union Financial Services, Inc. agreed to pay civil penalties and restitution to victims of fraud totaling $586 million to resolve actions brought by the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN), Department of Justice (DOJ), and Federal Trade Commission (FTC) for violations of the Bank Secrecy Act’s (BSA) anti-money
Non-Federally Regulated Banks Are Target of Proposed FinCEN Rules
Last month the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed new rules which would require non-federally regulated banks to implement Customer Identification Program (CIP) requirements related to the collection and verification of customer information. Financial institutions have until October 24, 2016, to comment on the proposed rule, which, if adopted, is estimated to
The “Fifth Pillar” of AML/BSA Compliance FinCEN Issues Final Rule for New Customer Due Diligence Requirements under the Bank Secrecy Act
For years, financial institutions have operated under the maxim that an effective anti-money laundering and Bank Secrecy Act compliance program (collectively “AML”) rests upon four pillars: (1) written policies and procedures; (2) a designated AML compliance officer; (3) independent testing of the institution’s AML program; and (4) implementation of an adequate employee training program. Now