2015 Year-End Review of BSA/AML and Sanctions Developments and Their Importance to Financial Institutions: Continued Trend in 2015 of Record-Setting Fines, Significant Criminal and Regulatory Enforcement Actions and Focus on Individual Accountability Means BSA/AML and Sanctions Compliance Must Remain a Focus of Boards of Directors and Senior Management of Financial Institutions

Sullivan & Cromwell LLP - March 3, 2016

This memorandum highlights what we believe to be the most significant developments and trends during 2015 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”).  In 2015, the overarching trend continued to be an intense focus on BSA/AML and sanctions compliance by multiple government agencies, combined with increasing regulatory expectations and significant enforcement actions and penalties, and an increased focus on individuals.  Government agencies continued to emphasize money-laundering and terrorist-financing risks, threats and vulnerabilities seen in prior years, as well as the emergence of certain new threats associated with advances in technology.  We do not see these trends abating in the near term.

This memorandum is aimed at keeping our 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 analysis presented in this memorandum or how the developments and trends we highlight may be relevant to your organization.