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C-Suite Review

C-Suite Financial Services Review: BSA/AML for nonbanking institutions

Buckley C-Suite Financial Services Review

Daniel P. Stipano

The requirements of the Bank Secrecy Act and anti-money-laundering laws are pervasive and longstanding, yet they continue to vex companies trying to comply with them. Regulators have hit virtually all large banks, and many nonbanks, with BSA/AML-related enforcement actions, resulting in large fines, deferred prosecution agreements, criminal consequences, and reputational damage.

New BSA/AML requirements are making compliance more, not less, challenging. The Financial Crimes Enforcement Network’s Customer Due Diligence rule, for example, has led to massive de-risking of bank accounts for money services businesses and other customers. This has made it more diffcult for customers to maintain accounts and added to the demanding nature and already high cost of BSA/AML compliance.

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