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Anti-money laundering and sanctions compliance challenges for custody services
Journal of Securities Operations & Custody,
8
(4),
341-355
(2016)
Abstract
US federal and state agencies are bringing more enforcement actions, and obtaining larger penalties than ever, for anti-money laundering (AML) and financial sanctions violations. US AML and sanctions obligations extend to all bank and broker– dealer operations, including custody operations. This paper describes the AML and sanctions frameworks applicable to bank and broker–dealer custody operations, and discusses three key compliance risks for those activities: accounts held for financial intermediaries, foreign financial institutions and microcap securities.
Keywords: anti-money laundering; OFAC; sanctions; compliance; AML; correspondent; microcap; enforcement
The full article is available to subscribers to the journal.
Author's Biography
Sharon Cohen Levin is a partner at the law firm WilmerHale and is a leading authority on anti-money laundering (AML), Bank Secrecy Act (BSA), economic sanctions and asset forfeiture. Sharon served for 19 years as Chief of the Money Laundering and Asset Forfeiture Unit in the US Attorney’s Office for the Southern District of New York (SDNY). Over the course of her career she has been recognised with 15 prestigious national and international awards and in 2015 was named one of the 75 ‘most accomplished female attorneys working in the legal profession today’ by The National Law Journal.
Franca Harris Gutierrez is a partner and vice chair of the Financial Institutions Practice Group at the law firm WilmerHale. Prior to joining WilmerHale, Franca was an attorney in Office of the Comptroller of the Currency (OCC). She maintains an active counseling and enforcement practice and represents banks, broker dealers, and financial services companies before the CFPB, the federal banking agencies, the New York Department of Financial Services and other regulatory bodies. She advises the world’s leading banks and securities firms in their most pressing and difficult anti-money laundering and sanctions matters.
Katrina Carroll is Chief Anti-Money Laundering Officer with LPL Financial. Ms. Carroll spent nearly a decade at the US Department of the Treasury and the Securities and Exchange Commission. In government, she worked to combat illicit finance, including money laundering, terrorist finance, narcotics trafficking, corruption and fraud and for four years worked with the SEC in the Office of Compliance Inspections and Examinations. Ms. Carroll was formerly counsel at the law firm WilmerHale where her practice focused on anti-money laundering, financial sanctions, and other financial crime matters.
Elijah Alper is a Director/Assistant General Counsel at Capital One. He specialises in FinTech and blockchain and has long been a notable voice in blockchain and digital currency industry, speaking out on pressing issues at industry events and authoring opinions in the developing subject area. Mr. Alper was formerly counsel at the law firm WilmerHale where he consulted financial institutions on AML compliance and best practices.
