Post at a glance:
- FinCEN imposes $8 million penalty against California’s biggest and oldest card club
- Club failed to implement and maintain an effective anti-money laundering (AML) program and failed to detect, deter, and report suspicious transactions
- Enforcement action serves as valuable reminder of scope of Bank Secrecy Act (BSA)
As mentioned in our prior AML Update, the U.S. Financial Crimes Enforcement Network (FinCEN) continues to aggressively enforce anti-money laundering and other financial crimes laws.
The latest target? California’s biggest and oldest card club, Artichoke Joe’s.
Bass, Berry & Sims’ Government Contracts & International Trade blog features news, commentary and insight on the demanding and ever-changing regulatory environment of contracting with federal, state and local governments, and international trade issues when conducting a global business.