This article delves into a joint statement that was issued by the Federal Crimes Enforcement Network (FinCEN) and federal banking regulators, which clarified the due diligence obligations of banks under the Bank Secrecy Act (BSA). Additionally, the article examines the provisions of the BSA.
The article provides an analysis and subsequent conclusion as to the BSA and how banks should comply with the regulatory expectations.
Authors: Jeanine P. McGuinness, Partner, International Trade & Compliance, FCPA& Anti–Corruption, Matthew Moses,
Partner, White Collar, Investigations, Securities Litigation & Compliance, FCPA & Anti–Corruption, Daniel Nathan,
Partner, White Collar, Investigations, Securities Litigation & Compliance, Financial Services Litigation, Amy Walsh,
Partner, White Collar, Investigations, Securities Litigation & Compliance, and Ben Dobkin, White Collar Career Associate, White Collar, Investigations, Securities Litigation & Compliance, Internal Investigations, Orrick