Menu Home

Crawling from the Wreckage

The newly-posted episode of Mr. Watchlist’s DesigNation is about yesterday’s OFAC enforcement action against Comtech Telecommunications and Comtech EF Data. All you need to know: egregious violations, settlement larger than the base penalty, and only 1 mitigating General Factor… Hoo boy! What fun!

January 16, 2018: OCC adjusts its penalties for inflation

OCC BULLETIN 2018-1 Subject: Civil Money Penalties Date: January 16, 2018  To: Chief Executive Officers of All National Banks and Federal Savings Associations; Federal Branches and Agencies of Foreign Banks; Department and Division Heads; All Examining Personnel; and Other Interested Parties Description: Notice Adjusting Civil Money Penalties for 2018 Summary On […]

OCC issues updated Enforcement guidance

  Office of the Comptroller of the Currency Ensuring a safe and sound Federal Banking System for All Americans   OCC BULLETIN 2017-48 Subject: Bank Enforcement Actions and Related Matters Date: October 31, 2017 To: Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; […]

Good read: New Zealand’s enforcement philosophy

From the Departmernt of Internal Affairs (DIA), it’s entitled “Minimising Harm – Maximising Benefit”… Minimizing Harm (Highlighting the AML section): Censorship We are concerned about the harmful effect objectionable and restricted material can have on the community – especially families, children, and young people. We are particularly concerned about the […]

You don’t have to be a big country…

To have financial crime enforcement. Swaziland has penalties for: Money Laundering Financing of terrorism Failure to establish and verify identity of persons and transactions Failure to maintain records Failure to maintain account in true name Failure to report suspicious transactions Failure to formulate and implement internal rules Failure to appoint […]