Key takeaways

• Federal and state regulators continue their focus on financial institutions’ compliance with anti-money laundering (“AML”) requirements.
• New measures include: (1) a Joint Fact Sheet by the Treasury Department and federal banking agencies regarding correspondent banking; (2) an OCC Comptroller’s Handbook booklet discussing, among other issues, AML risk management; (3) a consent order between the NYDFS and Mega Bank for violations of New York’s AML requirements; and (4) actions by FinCEN establishing AML program requirements for certain state-chartered banks and trust companies and expanding the scope of a Geographic Targeting Order for high-end residential real estate markets.