Enforcement Alert: $3.4 Billion TD Bank Settlement – Lessons for Compliance Teams
December 5, 2024Welcome to the Financial Crime Lab Q4 2024 Newsletter!
As we close out another year, the regulatory landscape continues to evolve at a rapid pace. Here’s your essential summary of the most significant AML and financial crime compliance developments from Q4 2024.
🔔 Key Regulatory Changes
1. FinCEN’s Beneficial Ownership Reporting Goes Live
Starting January 1, 2025, millions of U.S. companies must report beneficial ownership information to FinCEN under the Corporate Transparency Act. Key deadlines:
- Existing companies (formed before Jan 1, 2024): Must file by January 1, 2025
- New companies (formed in 2024): Must file within 90 days of formation
- New companies (formed after Jan 1, 2025): Must file within 30 days of formation
2. EU AML Package Advances
The European Union’s comprehensive AML reform package continues its legislative journey, with the Anti-Money Laundering Authority (AMLA) expected to be fully operational by 2025. Key changes include:
- Harmonized customer due diligence requirements across member states
- Enhanced supervision of high-risk sectors including crypto assets
- New €10,000 cash payment limit across the EU
3. FATF Updates Grey List
FATF’s October 2024 plenary session resulted in changes to the grey list. Compliance teams should review their country risk assessments and update enhanced due diligence procedures accordingly.
📊 By the Numbers
- $4.3 billion – Total AML fines globally in 2024
- 47% – Increase in crypto-related SARs filed
- 23 – Countries currently on FATF’s grey list
✅ Action Items for Your Team
- Review and update your beneficial ownership procedures
- Conduct a year-end risk assessment refresh
- Ensure 2025 training calendars include new regulatory requirements
- Update transaction monitoring scenarios for emerging typologies
Stay compliant, stay ahead. Questions about any of these updates? Contact our team for a consultation.