Potential Issues During Anti-Money Laundering Investigations

 Given the scope of the federal anti-money laundering statutory framework (and underlying body of federal regulations), there are numerous issues that have the potential to trigger DOJ, FBI, and FinCEN investigations. These investigations will often involve the DOJ’s Money Laundering and Asset Recovery Section (MLARS) and/or the Money Laundering Unit of the FBIs’ Criminal Investigative Division. This is why it’s important to put an Anti-Money Laundering Lawyer from Oberheiden P.C. on your side today.


Some examples of issues that can lead to scrutiny – and potentially lead to civil or criminal charges – in the area of anti-money laundering compliance include:


Failure to comply with know your customer (KYC) requirements

Failure to comply with Suspicious Activity Report (SAR) requirements

Failure to timely report transactions or activity that raise AML concerns

Failure to establish and implement adequate internal AML policies and procedures

Failure to register a money services business (MSB) or other entity as required by law

Engaging in financial transactions involving specially designated nationals or other blocked persons as designated by the Office of Foreign Assets Control (“OFAC”)

Engaging in other financial transactions which indicate a failure to comply with the federal anti-money laundering requirements

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