ACAMS Midyear Review: 2019 Compliance

Developments and Challenges

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 MODERATOR
Kieran Beer
Director of Editorial Content and Editor-in-Chief
ACAMS

SPEAKERS
Sarah Runge
Head of FCC Regulatory Strategy
Credit Suisse

Colby Adams
Managing Editor
ACAMS moneylaundering.com

Daniel Bethencourt
Reporter
ACAMS moneylaundering.com
 Speakers (cont.)

Koos Couvee
UK Senior Reporter
ACAMS moneylaundering.com

Valentina Pasquali
Washington Senior Reporter
ACAMS moneylaundering.com
 Cryptocurrency/Virtual Assets
I. US Regulatory Actions
II. Recent Cases from Europe
III. FATF Virtual Assets Guidance

Peer-to-Peer Cryptocurrency Exchangers Must Adopt AML Programs: FinCEN

Individuals who charge a fee to exchange bitcoins and other cryptocurrencies for government-issued banknotes must
register, comply with anti-money laundering rules and report suspicious transactions, same as any company, according
to the U.S. Treasury Department. May 15, 2019 https://www.moneylaundering.com/news/peer-to-peer-
cryptocurrency-exchangers-must-adopt-aml-programs-fincen/

Dark Web Cases Show Pitfalls of Laundering Funds Through Cryptocurrency: Sources
Bitcoins and other cryptocurrencies have carried a reputation as anonymous conduits for illicit transactions, especially
on the dark web. But recent federal cases show that the same financial instrument that keeps online black markets in
business is also their Achilles' heel. May 10, 2019 https://www.moneylaundering.com/news/dark-web-cases-show-
pitfalls-of-laundering-funds-through-cryptocurrency-sources/
 Financial Innovation/RegTech
I. FinCEN
II. OCC
III. Europe
FinCEN 'Open' to Innovation, Plans Regular Discussions on Emerging Technologies
The U.S. Treasury Department will provide financial institutions more "regulatory clarity" on how they can deploy artificial
intelligence and other technologies to comply with the Bank Secrecy Act, a senior official said. 12/04/18
https://www.moneylaundering.com/news/fincen-open-to-innovation-plans-regular-discussions-on-emerging-technologies/

OCC Chief Gives Large Banks 'B' Grade for CDD Rule Compliance
National banks have generally succeeded in their efforts to comply with the Treasury Department's customer due-diligence rule in
the first year since the measure took effect, the U.S. Comptroller of the Currency said Monday. 04/15/19
https://www.moneylaundering.com/news/occ-chief-gives-large-banks-b-grade-for-cdd-rule-compliance/

Largest Dutch Banks Plan Shared KYC Database

The three largest banks in the Netherlands will soon launch a pilot platform for sharing customer due-diligence data with each
other in efforts to streamline know-your-customer processes involving corporate clients. 01/11/19
https://www.moneylaundering.com/news/largest-dutch-banks-plan-shared-kyc-database/
 US BSA/Regulatory Reform& Congress
I. BSA Reform/The COUNTER Act
II. Beneficial Ownership
III. Congressional Inquiry into Trump Bank Transactions?
US House Committee Approves Broad AML Overhaul
U.S. legislation aimed at enhancing financial-intelligence sharing, privacy protections and training of examiners who measure
compliance with the Bank Secrecy Act came a step closer to becoming law on Thursday after clearing its first congressional hurdle.
05/09/19 https://www.moneylaundering.com/news/us-house-committee-approves-broad-aml-overhaul/

US Officials Eye Budget Boost for FinCEN, OFAC

U.S. officials have asked Congress to approve millions of dollars in additional funding for the Financial Crimes Enforcement
Network and the Office of Foreign Assets Control for the next fiscal year, congressional testimony and budget documents show.
05/16/19 https://www.moneylaundering.com/news/us-officials-eye-budget-boost-for-fincen-ofac/

Senate Democrats Urge FinCEN to Investigate Reported Suppression of Trump SARs

Democratic senators pressed a senior U.S. Treasury Department official Tuesday to investigate complaints that Deutsche Bank
ignored suspicious transactions involving U.S. President Donald Trump, his son-in-law and their businesses in 2016 and 2017.
05/21/19 https://www.moneylaundering.com/news/senate-democrats-urge-fincen-to-investigate-reported-suppression-of-
trump-sars/
I. OFAC Guidance
Sanctions
II. Iran Europe Vs. US
III. North Korean example

In New Guidance, OFAC Advises Banks and Other Firms on Sanctions Compliance
Companies may reduce the severity of penalties assessed against them for violating U.S. sanctions if the compliance programs they had in
place when the infractions occurred were otherwise "effective," according to the Treasury Department. 5/02/19
https://www.moneylaundering.com/news/in-new-guidance-ofac-advises-banks-and-other-firms-on-sanctions-compliance/

EU Officials Vow to Protect Firms from Helms-Burton Lawsuits

The transatlantic rift over extraterritorial enforcement of U.S. laws and sanctions widened Thursday after the EU's top diplomat pledged to
shield European firms from newly authorized lawsuits in the United States for doing business on expropriated American property in Cuba.
05/02/19 https://www.moneylaundering.com/news/eu-officials-vow-to-protect-firms-from-helms-burton-lawsuits

North Korean Ship Owner Routed Payment Through New York Banks: US Officials
Three unwitting banks in the United States processed transactions tied to at least $750,000 in maintenance costs for one of North Korea’s
largest vessels before its seizure by U.S. authorities Thursday, New York federal prosecutors said. 05/09/19
https://www.moneylaundering.com/news/north-korean-ship-owner-routed-payment-through-new-york-banks-us-officials/
 First-Half 2019 Enforcement Actions
I. Sanctions Related – Unicredit and Standard Chartered (May, April)
II. Europe – FCA and Beyond

Standard Chartered Settles 5-Year Global Sanctions Investigation, Will Pay $1.1 Billion
Standard Chartered Bank must pay more than $1 billion and extend the terms of its 2012 deferred prosecution agreements, or
DPAs, with U.S. state and federal agencies by two years for falsifying records and violating sanctions, U.S. and U.K. officials
announced Tuesday. O4/10/19 https://www.moneylaundering.com/news/standard-chartered-settles-5-year-gobal-sanctions-
investigation-will-pay-1-1-billion/
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 Today’s Speakers
Kieran Beer Koos Couvee
kbeer@acams.org kcouvee@acams.org
ACAMS moneylaundering.com
ACAMS
Valentina Pasquali
Colby Adams vpasquali@acams.org
cadams@acams.org ACAMS moneylaundering.com
ACAMS moneylaundering.com

Daniel Bethencourt
dbethencourt@acams.org
ACAMS moneylaundering.com
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