2014 Year-End Review of U.S. BSA/AML and Sanctions Developments and Their Importance to Financial Institutions: BSA/AML and Sanctions Compliance Continued to Be a Focus of Boards of Directors and Management of Financial Institutions as 2014 was Marked by Record-Setting Fines and Precedent-Setting Criminal Prosecutions and Enforcement Actions for Violations of BSA/AML and Sanctions Laws

Sullivan & Cromwell LLP - January 29, 2015

This memorandum highlights what we believe to be the most significant developments during 2014 for financial institutions with respect to U.S. Bank Secrecy Act/anti-money laundering (“BSA/AML”) and U.S. sanctions programs, including sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and identifies significant trends.  The overarching trend that is likely to continue for the foreseeable future is an intense focus on BSA/AML and sanctions compliance by multiple government agencies, combined with increasing regulatory expectations and significant enforcement actions and penalties. 

This memorandum to clients represents the first in a series of tools and materials we plan to introduce in the coming months aimed at keeping clients and practitioners informed of regulatory and enforcement developments in the areas of BSA/AML and OFAC sanctions.  We encourage you to contact us if you have any questions about the information and issues presented in this memorandum or how the developments and trends we highlight may be relevant to your organization.