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Enforcement Action Against Riggs Bank
By AM Henry
Riggs Bank entered into a consent agreement with FinCEN and paid a $25 million civil penalty.  |
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Enforcement Action Against Hartsfield Capital Securities
By AM Henry
Hartsfield Capital Securities entered into a consent to the assessment of a civil money penalty in the amount of $10,000 for failure to obtain information on correspondent accounts and an inadequate AML program. |
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The Topology of USAPA Enforcement
By A Henry & E Herrera
The most powerful tool for compliance officers, after the regulations themselves, are enforcement case studies. These “topologies of failure” provide concrete examples of how rules are being applied and what errors of omission or commission result in penalties. Eight enforcement actions are highlighted in this document: PayPal, Korea Exchange Bank, Leasecomm, Greenville Riverboat, Western Union, Banco Popular, Great Eastern Bank & Sovereign Bank.
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