Practice Highlight: AML & Sanctions Enforcement and Compliance
S&C is well-positioned to advise financial institutions and other clients through the complex and constantly changing areas of anti-money laundering (AML) and economic and trade sanctions.
AML and sanctions requirements present significant risks for financial institutions and other clients, as evidenced by the number of recent high-profile enforcement actions. Financial institutions and other clients are increasingly susceptible to penalties reaching the hundreds of millions or in some cases the billions of dollars, and even criminal prosecution, concerns deserving the attention of boards of directors and senior management, and necessitating the constant evolution and tailoring of AML and sanctions compliance programs to effectively manage risk in the current environment.
The Group includes practitioners who have provided counsel in nearly every high-profile AML and sanctions-related regulatory enforcement action and law enforcement proceeding involving a financial institution in the past decade. The team consists of former government officials from the U.S. Attorney’s Office, the New York State Banking Department (now the New York Department of Financial Services) and the Board of Governors of the Federal Reserve System, as well as former officials from the Federal Reserve Bank of New York and the New York Stock Exchange (now the Financial Industry Regulatory Authority) Enforcement Division. They have played a key role in advising on issues under the USA Patriot Act and enhanced AML program requirements, as well as on initiatives designed to bring greater transparency to the financial system. S&C was instrumental in drafting various industry guidelines, such as those affecting correspondent banking AML compliance and principles for transparency of financial transactions.
The Group has launched the AML and Sanctions Watchlist, a blog dedicated to keeping senior leaders at major financial services firms informed about developments in AML and sanctions enforcement and compliance. The blog explains key developments in enforcement and regulatory expectations as they arise in real time, providing high-level takeaways.