SFO Handbook Update: An In-depth Look

May 27, 2020 best practices, compliance, SFO guidance

What Does the SFO Handbook Update on Evaluating Compliance Programs Tell Us About Designing an Effective Compliance Program? The UK’s Serious Fraud Office (“SFO”) updated its Operational Handbook to include a chapter on Evaluation of Compliance Programs on January 17, 2020 (“the SFO Guidance”). Many analysts have reviewed the 8-page […]

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Increased AML Enforcement in Europe (Part 2 of 2)

April 08, 2020 aml, aml enforcement, EU, europe, financial crime

EU officials are still working on re-introducing a controversial fincrime compliance blacklist of “high-risk third countries” to help financial service firms better risk-assess certain jurisdictions for financial crime threats.

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Sapin II in Practice: Our First Look

August 06, 2019 ABAC, AFA, Sapin II

What are the key failures and program trends OFAC has highlighted in major enforcement actions against financial institutions and corporations?

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In what appears to be a flurry of updates and newly-issued regulatory guidance (see Steele’s coverage of OFAC guidance and DOJ’s Evaluation of Corporate Compliance Programs), the Financial Industry Regulatory Authority (“FINRA”) has just issued Regulatory Notice 19-18 (the “Notice”) to provide guidance to member firms regarding suspicious activity monitoring and reporting obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program).

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OFAC Issues New Framework for Sanctions Compliance

May 15, 2019 guidance, ofac, sanctions

The government agency charged with crafting the country’s sanctions programs has issued a rare and powerful piece of guidance.  It is a detailed, prescriptive framework laying out what it considers a strong compliance program to prevent companies from breaching sanction rules – a missive that could mitigate or negate a penalty, or, in its absence, elevate the endgame to egregious. 

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