Under US law, there is no express private right of action to enforce the BSA and courts have uniformly declined to infer an implied private right of action or duty of care.1
In the UK, while some provision is made in POCA for the commencement of criminal proceedings by private individuals, civil law claims for breach of contract, trust, or fiduciary duty, and the tort of deceit are more commonly brought against money launderers.
1 See James v. Heritage Valley Fed. Credit Union, 197 F. App’x 102 (3d Cir. 2006).