Congressional Research Service report cites Dr. Sharon Brown-Hruska on BSA/AML enforcement

05 February 2018

Washington, DC—A Congressional Research Service (CRS) report on the Bank Secrecy Act/Anti-Money Laundering (BSA/AML) enforcement, published 12 January 2018 and presented to brief the US Congress, extensively cites a 2016 report by former NERA Managing Director Dr. Sharon Brown-Hruska titled “Developments in Bank Secrecy Act and Anti-Money Laundering Enforcement and Litigation.” The CRS report, “Trends in Bank Secrecy Act/Anti-Money Laundering Enforcement,” quotes Dr. Brown-Hruska’s analysis of the increases in penalty frequency and size for BSA/AML penalties:

Nearly 90% of BSA/AML enforcement actions from 2012 through 2015 involved an assessment of money penalties, compared to less than half of such enforcement actions from 2002 through 2011. NERA also observed that BSA/AML penalties "have grown substantially in both absolute terms and as a proportion of firm capital."

It also notes Dr. Brown-Hruska’s finding that, for the largest BSA/AML violations, defendant financial institutions were often required to accept direct responsibility for company personnel who committed violations.

The full text of Dr. Brown-Hruska’s quoted report can be accessed here.

The CRS report, “Trends in Bank Secrecy Act/Anti-Money Laundering Enforcement,” can be found here.

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