The banks involved in the collaborative arrangement need to ensure that the shared resource conducting the BSA/AML independent testing is qualified and not involved in other BSA/AML functions at the ...

This article was originally published on April 11, 2025 on Law360 and is republished here with permission. On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement[1] with ...

Document that the AML program is effective, risk based, and reasonably designed. Maintain separate documentation of program design and execution. Draft clear descriptions of the roles and ...

In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering ...