From a financial crime perspective, financial institutions, fintechs, and others should proactively seek to understand directly and indirectly via their vast counterparty networks their nexus to Afghanistan. Below are some proactive steps organizations can and should take to get in front of what to date has been a slow moving response from governments. For example, of the new FinCEN-issued National AML Priorities, several are directly relevant to the current situation in Afghanistan - including, but not limited to: i) corruption, ii) terrorist financing, iii) transnational organized crime and iv) drug trafficking.
Practical AML/CFT & sanctions mitigants in the wake of the Afghanistan collapse:
The above is not exhaustive, but should provoke some additional questions and thinking for proactive compliance teams.
With the SEC whistleblower program setting new records in 2020 and with a renewed focus on whistleblowers as a result of the AML Act of 2020 (AMLA),...
The leak and subsequent investigation of the FinCEN Files hit the financial services industry hard this past week - resulting in sharp declines in...
Last week, following weeks of investigative reporting, The Washington Post compiled their various investigations into a piece called ‘A Pandemic of...