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US AML Enforcement Activity Moderately Increased in 2022 Despite Decline in Penalties

Law enforcement
US AML Enforcement Rebounds in 2022: A Closer Look at Penalties and Trends

According to data compiled by ACAMS moneylaundering.com, in 2022, US federal enforcement of anti-money laundering (AML) rules rebounded moderately in terms of volume but aggregate penalties related to AML declined. Four regulatory agencies, including the Office of the Comptroller of the Currency, Financial Crimes Enforcement Network, Federal Deposit Insurance Corp., and Federal Reserve, responded to 19 AML infractions through enforcement actions, nearly double the 11 actions in 2021 but far below the 40 actions in 2020.

Out of the 19 AML-related enforcement actions in 2022, eight carried a combined penalty of $384 million against individuals and institutions, compared to six actions in 2021 for $403 million and 20 actions in 2020 for $233 million. In addition, the total number of enforcement actions taken in response to violations of all types, including AML rules, sanctions, lending requirements, safety-and-soundness standards, and other obligations, dropped from 44 in 2021 to 38 in 2022, with AML constituting half of last year’s total.

FinCEN and the OCC’s $140 million assessment of combined penalties against Texas-based USAA Federal Savings Bank in March topped the list of monetary outlays related to AML in 2022, followed by the Federal Reserve’s collection of $20.4 million from the National Bank of Pakistan.

DFS fined the National Bank of Pakistan $35 million, following the Federal Reserve’s action against it, after discovering “serious” transaction-monitoring issues, “significant” managerial shortcomings, and other compliance-related flaws. DFS then finalized a consent against MoneyGram International in which the company agreed to pay $8.3 million after six of its agents remitted tens of millions of dollars to China without proper scrutiny.

Although only six of the 13 penalties, disgorgements, and other monetary resolutions disclosed by the Justice Department or New York’s Department of Financial Services in 2022 covered AML infractions, the combined amount was $2.1 billion, up from $357 million in 2021.

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