In a recent article for The Review of Banking & Financial Services, Debevoise lawyers Helen V. Cantwell, Meryl Holt Silverman and Elizabeth Costello address much-discussed trends in BSA/AML matters—trends include an increased focus on the prosecution of individuals and a drop in the number of corporate criminal cases.
Additionally, the authors provide insight on the DOJ’s evolving approach to AML enforcement and discuss the cases that represent the “new normal” for holding individual wrongdoers liable, including the deprioritization of corporate penalties for institutional BSA/AML failures.
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