Two of FinCEN's recent enforcement actions have involved international movement of money through an institution with an inadequate compliance program. ABN AMRO and Oppenheimer and Company have been charged with BSA violations. In both cases, the institutions were missing key elements of a compliance program and understaffed the compliance function, particularly the review of transactions. In both cases, the companies failed to detect and report suspicious activity such as funds transfers with no relationship to accounts. The warning is clear: money coming in must be looked at as carefully as money going out.
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