Trade-Based Money Laundering: Detection Strategies for Financial Institutions
October 10, 2024Exam Ready: Preparing for Your Next BSA/AML Regulatory Examination
October 24, 2024Q3 2024 Newsletter Edition
The third quarter brought significant regulatory developments across the globe. Here’s your summary of the key changes affecting AML and financial crime compliance programs.
🇺🇸 United States Updates
FinCEN Developments
- AML/CFT Priorities: FinCEN reaffirmed its 2024 priorities, emphasizing corruption, cybercrime, and domestic terrorism financing
- Investment Adviser AML Rule: Final rule extending BSA requirements to certain investment advisers (effective 2025)
- Real Estate GTO Expansion: Geographic Targeting Orders extended to additional metropolitan areas
OFAC Activity
- Continued expansion of Russia-related sanctions
- New designations targeting fentanyl precursor trafficking networks
- Updated guidance on sanctions compliance in the humanitarian sector
🌍 International Developments
FATF October Plenary
- Updated guidance on beneficial ownership and transparency
- New report on terrorist financing in the context of CSAM
- Grey list updates: monitoring of several jurisdictions’ progress
European Union
- AMLA (Anti-Money Laundering Authority) location decision: Frankfurt selected
- MiCA implementation guidance from ESMA and EBA
- New cash payment limits in effect across member states
United Kingdom
- FCA published updated Financial Crime Guide
- New requirements for cryptoasset firms marketing to UK consumers
- OFSI enforcement guidance updates
📊 Enforcement Trends
Key metrics from Q3 2024:
- $2.1 billion in global AML penalties announced in Q3
- Focus areas: Transaction monitoring failures, KYC deficiencies, sanctions violations
- Individual accountability: Increased personal liability actions against compliance officers
✅ Action Items
- Review FinCEN’s 2024 priorities and assess your program’s alignment
- If an investment adviser, begin preparing for new BSA obligations
- Update sanction screening for new designations
- Review FATF guidance on beneficial ownership
- Assess EU regulatory developments if operating in or with EU entities
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