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Highlights from 2019's AML Enforcement Activity


In this article, Ann Sultan, William Barry, and Kirby Behre explore 2019 themes in money laundering enforcement, including the U.S. government's continued focus on the importance of Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance programs, significant criminal cases involving economic sanctions violations, key AML regulatory developments, actions against individuals, and an important ruling from the U.S. Court of Appeals for the Ninth Circuit. Overall, this year saw U.S. authorities committing additional resources to combat money laundering, which puts additional pressure on companies to ensure AML and BSA compliance programs are up to date. As companies "approach 2020 and … look to evaluate their compliance priorities for the year," the authors wrote, "both financial and non-financial institutions should note the U.S. government's public announcements of additional dedicated anti-money laundering resources, coupled with continued efforts to target inadequate compliance programs, sanctions violations, and individuals."