Operation Chokepoint and the Brave New World of Criminal Liability

The U.S. Department of Justice and banking regulators have stepped up the pace of criminal, civil and administrative actions against banks, payment processors, money transmitters, and other financial institutions, for violations of the Bank Secrecy Act, including through a DOJ initiative known as “Operation Chokepoint.” Criminal charges for failing to maintain an effective Anti-Money Laundering Program, or for failing to file Suspicious Activity Reports, are no longer uncommon when the government believes, sometimes with the benefit of hindsight, that a financial institution missed “red flags” in connection with a customer’s account.

On October 30, DWT payments team member Jeff Coopersmith took part in a webinar that covered the regulatory and enforcement landscape, business risks, and compliance best practices in this area. To view the webinar, click here.