In the US, FinCEN and other agencies have engaged in vigorous AML enforcement against financial institutions over the past several years.  In February 2018, FinCEN prohibited the opening or maintaining of a correspondent account in the United States for or on behalf of ABLV Bank of Latvia.  And in the same month, the DOJ, Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System, and FinCEN announced $613 million in penalties against U.S. Bancorp and its subsidiary, U.S. Bank N.A. for violations of the BSA.  By mid-2018, the Office of the Comptroller of the Currency had initiated fifteen AML enforcement cases, triple the number of cases brought during 2017.  Over that one-year period, total penalties increased from $1 million to $137.9 million.

In the UK, the FCA has issued substantial fines against UK financial institutions for failure to maintain an adequate anti-money laundering control framework. For example, in 2017, the FCA fined Deutsche Bank £163m.  In other cases, the FCA has imposed restrictions such as preventing a firm from accepting deposits from new customers for a specified period of time.


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