FinCEN recently released the factors it will use when deliberating an action against a financial institution for Bank Secrecy Act violations. FTI Consulting’s Jaco Sadie, Michael Buffardi and Stephanie Fauerbach explore how discrete issues could trigger multiple FinCEN enforcement factors. On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN) published a statement identifying the factors it will consider when determining the...
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