In this Law360 article, Ian Herbert, Leah Moushey, and Therese Kuester analyze the Financial Crimes Enforcement Network's (FinCEN) recent $125 million settlement with UBS Financial Services Inc. for anti-money laundering (AML) compliance failures. The authors explain that the resolution "reinforces that regulators value prompt and effective remediation of program failures when evaluating and determining penalties for recidivists" and highlights how enforcement agencies continue to focus on risks associated with Latin America, narcotics trafficking, and cartel activity. 

The article notes that the settlement "demonstrates the importance of timely implementation of remediation commitments made in resolutions, and where delays or challenges are presented, communication with regulators is essential." The authors also observe that financial institutions should assess whether their AML controls are appropriately calibrated to address risks associated with transactions involving Latin America and other high-risk jurisdictions.