AML Compliance Program Handbook by MR Dominic Suszek
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AML Compliance Program Handbook

AML Compliance Program Handbook


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About the Book

Recent regulatory developments have compliance officers nationwide very concerned about their jobs and the possible consequences of actions (or inactions) taken while employed for financial institutions. Even when the hiring market for compliance professionals has been very active in recent years, the risks that come with the job cannot be overlooked. A decision adopted from a federal district court and regulations from the New York State Department of Financial Services finalized on June 30, 2016 and effective January 1, 2017 provide even more reasons for compliance officers at financial institutions to install robust BSA compliance programs in order to avoid personal liability. In U.S. Department of Treasury v. Haider, the Treasury Department's Financial Crimes Enforcement Network (FinCEN) alleged that MoneyGram's former chief compliance officer, Thomas Haider, failed to take sufficient actions to terminate, and failed to file Suspicious Activity Reports (SARs) related to transactions he had reason to believe were related to money laundering, fraud, or other illegal activity. FinCEN fined him $1 million and brought action in federal court to collect the fine. Haider sought dismissal of the fine, arguing that the Bank Secrecy Act applies to institutions, not individuals. The court disagreed and denied his motion, reasoning that the Bank Secrecy Act's civil penalties provision applies to "partners, directors, officers, and employees" of financial institutions. No final disposition has been reached in the case, but the district court's decision makes clear that FinCEN is empowered to impose personal liability on compliance officers. In addition to a $1 million fine, Haider faces a permanent ban from employment in the financial industry. Under this decision, compliance officers would be personally subject to both civil and criminal liability if their institution's anti-money laundering compliance programs are incapable of detecting and stopping illicit transactions.
About the Author: Dominic Suszek is the founder and CEO of Global RADAR(R). With more than 25 years of hands-on experience in the evolving global regulatory landscape in the financial services sector, Mr. Suszek has gained invaluable knowledge of a complex and ever-changing industry that has merged technology, compliance and operations. As a senior executive involved in all aspects of operations, technology and regulatory compliance, with particular emphasis on cost reduction, and enhanced compliance through better data management and simplified processes, he has acquired extensive knowledge of business requirements and regulatory expectations from supervisory agencies worldwide.


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Product Details
  • ISBN-13: 9781537192789
  • Publisher: Createspace Independent Publishing Platform
  • Publisher Imprint: Createspace Independent Publishing Platform
  • Height: 229 mm
  • No of Pages: 38
  • Series Title: English
  • Sub Title: A reference guide for managing your AML program
  • Width: 152 mm
  • ISBN-10: 1537192787
  • Publisher Date: 19 Aug 2016
  • Binding: Paperback
  • Language: English
  • Returnable: N
  • Spine Width: 2 mm
  • Weight: 113 gr


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