Anti-Money Laundering compliance programs
Anti-money laundering compliance programs in Financial & Capital Markets are under simultaneous pressure from the Financial Crimes Enforcement Network, the U.S. Securities and Exchange Commission, and the European Banking Authority, each advancing distinct but overlapping requirements on customer due diligence, beneficial ownership verification, and transaction monitoring controls. The Corporate Transparency Act's beneficial ownership reporting framework has forced compliance teams to reconcile internal CDD procedures against FinCEN's updated beneficial ownership database access rules, a reconciliation that is still unresolved at many institutions. The gap between what regulators expect and what programs actually document is where enforcement actions are being built.
Watch
- FinCEN beneficial ownership database access rules: integration deadlines for covered institutions
- SEC's broker-dealer AML examination priorities signaled in 2024 exam findings letters
- EBA's revised AML/CFT guidelines on correspondent banking de-risking practices
- Surge in FinCEN Suspicious Activity Report filing deficiencies cited in recent consent orders
- FATF Recommendation 16 wire transfer traceability: APAC jurisdiction implementation gaps
Recent material activity in Financial & Capital Markets
Active monitoring in place across Financial & Capital Markets. Material developments related to anti-money laundering compliance programs will appear here as they are published.