How do BSA Prosecutions Start?
The ABA Money Laundering Enforcement Conference pulled together a panel to explain the process of criminal prosecutions for money laundering. Cases begin from any of several sources. According to Cynthia Stone, Senior Trial Attorney with DOJ, the Department looks at money laundering issues with a scope-like view of the full industry. A specific individual may be under investigation for a substantive crime and the investigation leads to bank accounts and banking activities. Stone stated that this is the most common way that investigators are led to the financial institution. In effect, the transaction leads to the institution.
Other cases are based on referrals by regulators. Stone stressed that this is not a common source for cases but does occur from time to time. Investigators also read the papers. Sometimes a news story will provide the impetus for an investigation. Once started, the investigator follows the information and leads.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 13, 11/05
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