Money Laundering, Bank Secrecy and Sanctions Regulators Expand Remits

U.S. government agencies are expanding their remits, crossing traditional dividing lines, collaborating and even competing as they pursue anti-money laundering, Bank Secrecy Act and sanctions issues, judging by 2023's developments. The year saw executive enforcers turning to Congress for more power, and an executive order that made foreign financial institutions liable for certain transactions related to export-control, even without a U.S. nexus. This article distills those and other related policy and enforcement insights shared during a recent Gibson Dunn webinar. See “Knowing Your Customer’s Customer? Sanctions and Tri-Seal Guidance Heighten Expectations on Companies” (Nov. 8, 2023).

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