Recent developments on the US and foreign law enforcement fronts, alongside signals of a potential shift in Bank Secrecy Act (BSA) obligations, renew pressure on entities to ensure that the quality of their beneficial ownership compliance and third-party screening practices meets rising expectations.
Late last year, prosecutors unsealed a 67-page indictment detailing the first US criminal charges stemming from revelations in the Panama Papers, the 11.5 million-document treasure trove leaked in 2016 detailing offshore transactions. Early last month, reports emerged that the global tally of fines and back taxes owed resulting from the release of the Panama Papers edged above the US$1.2 billion mark.
On the US legislative and regulatory front, meanwhile, debate over brewing AML reforms remains in the news, raising questions about expectations related to beneficial ownership compliance requirements. As law enforcement scrutiny of offshore companies masking sham foundations and illegal shell companies grows — and regulators' expectations and powers expand — so too does the requirement for enhanced diligence on and monitoring of investors or clients.
— In late 2018, the US Senate Banking Committee heard the testimony of representatives from Treasury Department's FinCEN, the OCC, and the FBI in connection with a draft bill that includes a substantial revamp to the BSA.
— FinCEN and OCC joined the Federal Reserve, FDIC, and the National Credit Union Administration in December with a statement urging banks to "consider, evaluate, and where appropriate, responsibly implement innovative approaches to meet their [BSA/AML] obligations."
— A flurry of end-of-2018 AML and BSA enforcement actions was followed by an announcement by FINRA and the SEC’s Office of Compliance Inspections and Examinations that AML compliance will be an even higher priority for 2019.
Our take? The sharpening focus on attacking global illicit finance means that thorough beneficial ownership research and robust third-party screening have never mattered more.
— IntegrityRisk Owner√ s up to the task when it comes to beneficial ownership diligence. Our experienced research team uses its global business knowledge and native-level fluency in multiple languages to conduct focused, accurate public record checks.
— IntegrityRisk Screen√ meets all the elements of strong, defensible, and consistent third-party screening compliance. A comprehensive solution that screens every third party without exception, Screen√ seamlessly augments your current compliance process and offers an option to monitor all third parties on an ongoing basis. .
Every day, we help clients meet regulatory requirements for just about any purpose, including complex transactions, private wealth matters, and third-party / vendor diligence. Contact us to learn more.