Policy Patty Toolkit 

Making the world a little more compliant one toolkit at a time.


SocGen Fined by NY's DFS for Economic Sanctions and AML Violations

Posted on November 20, 2018 at 6:50 PM
New York's Department of Financial Services (DFS) announced that it has entered into two consent orders with Societe Generale SA and its New York branch under which the bank will pay fines totaling $420 million for violations of laws governing economic sanctions and New York anti-money laundering laws. The order stems from a DFS investigation found that the bank executed billions of dollars in illegal and non-transparent transactions to parties in countries subject to embargoes or otherwise sanc... Read Full Post »

FINRA Fines LPL $2.75 Million for Complaint-Reporting and AML Program Failures

Posted on October 30, 2018 at 2:25 PM

FINRA fined LPL Financial, LLC $2.75 million for complaint-reporting and AML program failures that spanned a period of more than three years.

FINRA found that LPL failed to file or amend registered representatives’ Forms U4 or U5 to disclose dozens of reportable customer complaints. LPL too narrowly interpreted the requirement that a complaint contain “a claim for compensatory damages of $5,000 or more” to be reported. LPL incorrectly construed this phrase to mean that...

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FINRA Amends Capital Acquisition Broker Rule 331 to Conform to FinCEN's Final Rule on Customer Due Diligence Requirements for Financial Institutions

Posted on October 21, 2018 at 5:25 PM
FINRA filed for immediate effectiveness amendments to Capital Acquisition Broker (CAB) Rule 331 (Anti-Money Laundering Compliance Program) to reflect the Financial Crimes Enforcement Network's (FinCEN) adoption of a final rule on Customer Due Diligence Requirements for Financial Institutions (CDD Rule). On November 21, 2017, FINRA published Regulatory Notice 17-40 to provide guidance to member firms regarding their obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program) ... Read Full Post »

DFS Finds Multiple Deficiencies in Bank???s Compliance with Anti-Money Laundering Laws and Office of Foreign Asset Controls Regulations

Posted on October 12, 2018 at 10:05 AM

NY's Department of Financial Services (DFS) announced that it had fined United Arab Emirates-based Mashreqbank PSC and its New York branch $40 million for violations of U.S. Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) laws in the New York branch’s U.S. dollar clearing operations. Under a consent order, Mashreqbank must:

  • Immediately hire a third-party compliance consultant to oversee and address deficiencies in the branch’s compliance function, including c...

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Interagency Statement on Sharing Bank Secrecy Act Resources

Posted on October 8, 2018 at 2:05 PM

The U.S. Treasury and federal banking and credit union regulators issued a joint statement focusing on smaller institutions, allowing these operations to pool financial crime compliance resources to lower costs, improve efficiency and potentially get access to more expertise and greater independence.

The Financial Crimes Enforcement Network (FinCEN), the Office of the Comptroller of the Currency (OCC) Federal Reserve (Fed), Federal Deposit Insurance Corp. (FDIC) and National Credit Unio...

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European Commission welcomes agreement on stronger rules criminalizing money laundering

Posted on June 13, 2018 at 4:00 PM

The European Commission issued a statement on June 8th announcing more robust rules on the criminalization of money laundering and penalties for offenses. The new rules were first proposed in December 2016 and are intended to align money laundering offenses and sanctions throughout the European Union (EU), with a special emphasis on terrorism financing.

Directive’s Objective

The new directive aims at blocking access by criminals to financial resources, including those used f...

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CCO and AML Officer Charged with SAR Violations

Posted on May 17, 2018 at 8:35 AM

The SEC charged Jerard Basmagy, a chief compliance officer and AML Officer, along with two broker-dealers with failing to file Suspicious Activity Reports (SARs) after red flags came up for the sale of 12.5 billion shares of penny stocks. Basmagy was charged with willfully aiding and abetting and causing his firm's AML violations. He agreed to pay the SEC a $15,000 penalty and a bar from the securities industry and the penny stock business for at least three years. He settled without admittin...

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FinCEN issued FAQs on CDD Requirements

Posted on April 7, 2018 at 4:00 PM

The Financial Crimes Enforcement Network (“FinCEN”) issued a long-anticipated second list of FAQs on the implementation of the Customer Due Diligence Requirements for Financial Institutions (“CDD Rule”). The final deadline for implementation is May 11, 2018.

While the FAQs address only some of the concerns including the following:.

• Interaction of the beneficial ownership threshold with other AML program obligations

• Collection of b...

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FINRA Fines Aegis Capital Corp. $550,000 for Anti-Money Laundering and Supervision Rule Violations

Posted on March 28, 2018 at 5:10 PM

FINRA fined Aegis Capital Corp. $550,000 for failing to have adequate supervisory and anti-money laundering (AML) programs tailored to detect "red flags" or suspicious activity connected to its sale of low-priced securities. The fine is based on the following findings:

• Aegis’ supervisory system for trading in delivery versus payment (DVP) accounts was not reasonably designed to satisfy its obligation to monitor and investigate trading in DVP accounts, particularly in low-p...

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U.S. Bancorp is Charged for Violations of The Bank Secrecy Act

Posted on February 15, 2018 at 1:40 PM

The United States Attorney for the Southern District of New York, announced criminal charges against U.S. Bancorp (“USB”) consisting of two felony violations of the Bank Secrecy Act (“BSA”) by its subsidiary, U.S. Bank National Association (the “Bank”), the fifth largest bank in the United States, for willfully failing to have an adequate anti-money laundering program (“AML”) and willfully failing to file a suspicious activity rep...

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