Skip to main content

Money Laundering Enforcement Thrives in COVID-19 Era


In this article, Miller & Chevalier Members William Barry, Kirby Behre, and Ann Sultan discuss U.S. money laundering enforcement efforts during the COVID-19 pandemic and the expectation that U.S. authorities will continue to prioritize AML compliance, specifically risk-based compliance. Financial Crimes Enforcement Network guidance identifying potential money laundering risks associated with COVID-19 and recent actions against two individuals for money laundering activity demonstrate U.S. regulators' focus on AML enforcement, the authors stated. "Both the von der Goltz and Hoskins cases underscore the resources that U.S. enforcement agencies continue to devote to prosecuting money laundering and related crimes. Recent corporate guidance and enforcement activity underscore the attention authorities are paying to the resources that financial institutions and others devote to their AML programs, including in the critical assessment of their risk," the authors wrote. "Authorities have signaled that they believe the current times are yielding certain specific risks, and institutions would do well to ensure that their assessments of risk are up to date."