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Blog Posts

OCC Orders Bank of America to Overhaul AML and Sanctions Compliance Programs
AML Compliance

Bank of America has publicly acknowledged the cease-and-desist order issued by the OCC and affirmed its commitment to improving its anti-money laundering (AML) and sanctions compliance programmes. The bank has been engaging with regulators over the past year to address existing gaps and has stated that it is well-positioned to meet the requirements outlined in the enforcement action. In its October 2024 filing, Bank of America had already indicated that regulatory discussions were underway and signalled the likelihood of future actions. Despite the seriousness of the OCC's findings, the bank does not anticipate any material adverse financial impact resulting from the order.

North America
Financial Institutions
Application of Open Source Intelligence (OSINT) Framework in the Modern Era
Sanctions Compliance

In today’s data-driven world, the Open Source Intelligence (OSINT) framework has emerged as a powerful approach to extracting actionable insights from publicly accessible information across digital platforms. From cybersecurity and national security to business strategy and humanitarian response, OSINT enables organisations to monitor, analyse, and respond to developments in real-time—cost-effectively and ethically. It leverages diverse sources such as social media, news outlets, public records, and geospatial data, turning unstructured data into strategic intelligence through automated tools and expert analysis. While its advantages include scalability, comprehensive coverage, and legal transparency, OSINT also presents challenges related to data overload, accuracy, and ethical use. As technology advances, the integration of AI, real-time visualisation, and cross-domain intelligence sharing is poised to enhance OSINT’s impact, making it a cornerstone of modern intelligence practices in both public and private sectors.

Europe
The OFAC SPFS Alert and Its Implications for Global Financial Compliance
Sanctions Compliance

The OFAC alert regarding Russia's SPFS system highlights the growing challenges financial institutions face in navigating sanctions compliance. With SPFS facilitating potential sanctions evasion, banks must reassess their risk management frameworks, scrutinise correspondent relationships, and leverage specialised data sources to identify exposures. Divergent regulatory approaches between the US and EU further complicate compliance efforts, necessitating robust, adaptable strategies. Proactive measures, including the integration of advanced screening tools and real-time data, are essential for institutions to mitigate risks and uphold the integrity of the global financial system.

North America
Financial Institutions
The Corporate Transparency Act: A New Era for Business Accountability
AML Compliance

The Corporate Transparency Act marks a significant advance in the fight against financial crime by requiring companies to disclose beneficial ownership information to US authorities. Aimed at increasing transparency, closing regulatory gaps, and aligning with international standards, the Act imposes new compliance obligations on many small and medium-sized businesses. While it strengthens accountability and corporate governance, it also presents challenges around privacy, enforcement, and administrative burden, highlighting the need for businesses to establish robust compliance systems and embrace transparency as a core principle of responsible operation.

North America
The New York State Department of Financial Services: Safeguarding Financial Integrity
AML Compliance

The New York State Department of Financial Services (NYDFS) serves as a central regulatory authority overseeing a broad spectrum of financial institutions within New York. Established in 2011, the department's mission encompasses the supervision of banks, insurance companies, and emerging financial technologies, ensuring compliance with state laws and protecting consumers from financial misconduct. Through rigorous enforcement, consumer education, and the promotion of cybersecurity and innovation, the NYDFS maintains the integrity and stability of New York's financial system, reinforcing its status as a global financial leader.

North America
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