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AML Enforcement: Avoiding Personal Liability

In the second of a three-part series, learn how compliance officers can protect themselves in the new anti-money laundering landscape.

By Greg Marshall, Erin Sullivan | Updated on March 20, 2016

In February 2014, the Financial Industry Regulation Authority, the self-regulatory body for the U.S. securities industry, suspended a former global anti-money laundering compliance officer at Brown Brothers Harriman & Co. and assessed a record $8 million fine against the firm for its inadequate Bank Secrecy Act/anti-money laundering program and lack of oversight related to suspicious penny stock transactions. The former compliance officer personally paid $25,000 under the settlement he and Brown Brothers Harriman entered with FINRA.

And in December 2014, the U.S. Attorney’s Office for the Southern District of New York filed a civil enforcement action against a former chief compliance officer for MoneyGram to enforce a $1 million penalty assessed by the U.S. Treasury Department’s Financial Crimes Enforcement Network. FinCEN based its assessment on the officer’s alleged role in compliance violations related to the use of MoneyGram’s services by perpetrators of fraudulent telemarketing and other schemes.

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