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An unprecedented wave of sanctions and export controls against Russia, and to a lesser extent Belarus, requires financial institutions from the West and other allied countries to take immediate steps to understand the impact of the complex requirements and ensure compliance.
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There was a time when financial misconduct meant a rogue trader racking up losses on a stock market bet he wasn’t authorised to make or a Ponzi scheme where crooked asset managers spent investors’ money on a posh lifestyle. But the definition of misconduct by financial actors has changed, and greatly expanded, in the past decade-and-a-half due to big scandals, even bigger financial catastrophes,…
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Transparency and consequences can be powerful leadership deterrents. For the board and CEO and their personal brands, the critical question is, what will key decision-makers in their organisation do in situations when no one is watching?
When the subject of ethical and responsible business behavior arises, Warren Buffett advises managers to evaluate every action they take — and not just by legal…
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In the third decade of the 21st century, smart companies and boards across all industries recognise that the pace of technological change continues to unfold at warp speed. The question in the boardroom a decade ago — “Should we invest in digital transformation?” — has transitioned to a different question today: “How much should we invest and, more important, how fast should we invest, given our…
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It’s been fewer than two decades since the term ESG, or Environmental, Social and Corporate Governance, was coined in a landmark report commissioned by the United Nations. ESG has become a hot topic for politicians and regulators, as events like natural disasters and protests on racial and social inequity have led to public calls to action for fundamental changes to the way society interacts with…
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Introduction
On May 8, 2020, the Agencies[1] released a final version of the Interagency Guidance on Credit Risk Review Systems. This final guidance applies to all institutions supervised by the Agencies and supersedes regulatory expectations for credit risk review systems documented in Attachment 1 - Loan Review Systems – of the 2006 Interagency Policy Statement on…
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Expectations are that the financial services industry will experience a more challenging regulatory environment under the Biden administration than under the former administration[1]. Those who have been tapped to lead the various regulatory agencies – and even those thought to be in contention for key agency roles – have signaled their supervisory priorities, many of which align with key…
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What to Expect and When
The main headline about the Anti-Money Laundering Act of 2020 (AML Act) has been that the United States finally moved to address a long-standing gap in its anti-money laundering (AML) regime by establishing a national registry of beneficial owners. Not reading beyond that headline, however, would be a mistake because the AML Act includes many other provisions that, taken…
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Your monthly compliance news roundup
BSA/AML Examination Manual Updates from FFIEC
On April 15, 2020, the Federal Financial Institutions Examination Council (FFIEC) released updates to the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) examination manual. The manual is used to evaluate an institution’s compliance with the Bank Secrecy Act and anti-money laundering requirements. This…
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Your monthly compliance news roundup
FinCEN: BSA Reporting Obligations Remain Crucial During COVID-19 as Fraud Trends Rise
The first case of the novel coronavirus (COVID-19) in the United States was confirmed on January 20, 2020, two months after the first known cases are believed to have originated in China. While the world turned its attention to the virus and finding effective treatment…
