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The New Era of Regulatory Enforcement: A Comprehensive Guide for Raising the Bar to Manage Risk by Timothy P. Hedley, Richard H. Girgenti

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Chapter 4

Money Laundering

Teresa A. PesceJohn F. Caruso

Few industries are more heavily regulated and scrutinized than financial services, particularly in the area of anti–money laundering (AML) and financial crime. In their effort to keep the financial system safe, the authorities have taken enforcement activity to unprecedented heights, in terms of both the level of scrutiny applied to a firm’s AML/Bank Secrecy Act (BSA) Program and the severity of regulatory responses if and when programmatic weaknesses are identified.

The sources of the underlying legal and regulatory obligations are not new. For many years, the BSA was the primary source of AML regulation in the United States. Enacted in 1970, the BSA initially established requirements ...

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