Buckley Sandler Webcast: Individual Exposure - FinCrimes Professionals in the Spotlight
In a series of speeches last year, Comptroller Thomas J. Curry, Deputy Attorney General James Cole, and FinCEN Director Jennifer Shasky advised that regulators and law enforcement agencies were actively studying the issue of individual liability for AML program violations. Each “warned” that it was only a matter of time before the issue was joined.
True to their word, in December 2014, the Financial Crimes Enforcement Network (FinCEN) issued a $1 million civil money penalty against Mr. Thomas E. Haider (the former CCO for MoneyGram International) for failing to ensure that his company abided by the anti-money laundering (AML) provisions of the Bank Secrecy Act (BSA). Concurrently, the U.S. Attorney’s Office for the Southern District of New York (SDNY) filed a complaint in U.S. District Court that seeks to enforce the penalty and to enjoin Mr. Haider from employment in the financial industry.
The MoneyGram action follows the penalty FINRA imposed on Brown Brothers Harriman and its Global AML Compliance Officer, Harold A. Crawford, for failures in its AML program. It is widely expected that this is just the beginning in what is expected to be a range of actions against individuals for AML program failures and it is assumed as well that liability may not be limited to compliance officials but could likely reach C-suite executives and board members.
In this webcast, we will examine these recent enforcement actions against FinCrimes compliance professionals as well as evaluate the lessons they offer about how to structure and manage a FinCrimes compliance program to avoid adversity.
When: Thursday, January 22, 2015 from 12:00 to 1:30 pm EST
- Polly Greenberg, Chief, Major Economic Crimes Bureau at the New York County District Attorney’s Office
- Richard Small, Senior Vice President for Enterprise-Wide AML, Anti-Corruption and International Regulatory Compliance at American Express
James T. Parkinson focuses on international regulatory compliance counseling, corporate internal investigations, and enforcement defense litigation. He represents clients on a variety of criminal and civil enforcement actions, including Foreign Corrupt Practices Act (FCPA), securities fraud, insider trading, false statements, and environmental matters.
About Buckley Sandler's Financial Crimes Practice With more than 150 lawyers in Washington, DC, New York, Chicago, Los Angeles, and London, Buckley Sandler provides best-in-class legal counsel to meet the challenges of the nation's leading financial institutions as well as other corporate and individual clients. Buckley Sandler’s FinCrimes Practice supports financial services and other firms in designing, implementing, and testing compliance programs, and – as is increasingly necessary – in defending against enforcement actions and parallel civil litigation. Please visit our practice page and participate in our ongoing webcast series on FinCrimes topics.