Client Alert: New multi-front Enforcement Action Emphasizes Key AML Compliance Requirements

Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance Corporation (“FDIC”), and the New York Department of Financial Services (“NYDFS”). These concurrent actions resulted in a total of $25 million in civil penalties for failing to develop and implement an effective AML program in accordance with the Bank Secrecy Act (“BSA”) and New…
By: Jenner & Block