Panels on Forensic Accountants and BSA Exams at the 2015 New England IRS Representation Conference

IRS Rep ConferenceWe are looking forward to attending the New England IRS Representation Conference this Friday, November 20, 2015, at the Foxwoods Resort & Casino in Ledyard, Connecticut. It is hosted by Eric Green and his colleagues at Green & Sklarz LLC; the conference, which has really grown over the years, will address many topics, including current IRS and DOJ initiatives, payroll tax issues, and ethical issues presented by appearing before the IRS.  I will have the pleasure of speaking on a panel regarding the use of forensic accountants during criminal tax investigations, with co-panelists Larry Campagna and Noelle Geiger, and on a panel regarding Bank Secrecy Act exams by the IRS, with co-panelists Michael Villa, IRS CI Special Agent Maria Papageorgiou, and Larry Campagna.  … Read More

Federal Reserve’s AML/BSA Compliance Crackdown Continues

AML BSA ComplianceThis week the Federal Reserve Bank of San Francisco announced that East West Bank, based in Pasadena, California and with subsidiaries in China and Hong Kong, has entered into an agreement to strengthen its anti-money laundering (AML) and Bank Secrecy Act (BSA) compliance. The agreement covers many of the same areas as the New York Fed’s recent agreement with The Bank of Nova Scotia, which we discussed in a November 12 post, and calls for revamped compliance programs for key areas, including BSA/AML, Customer Due Diligence, and Suspicious Activity Monitoring and Reporting.

Of interest are two obligations the agreement imposes in connection with the Bank’s required Suspicious Activity Monitoring and Reporting.… Read More

NY DFS Cracks Down on Banks’ Anti-Money Laundering Deficiencies

Earlier this year, New York’s Department of Financial Services (“DFS”), the State’s banking and insurance regulator, announced that it was increasing and strengthening its enforcement efforts aimed at financial institutions’ anti-money laundering (“AML”) and Bank Secrecy Act (“BSA”) compliance deficiencies. The latest installment in the DFS’s crackdown on financial institutions came on November 5th, when the DFS and the Federal Reserve Bank of New York (the “New York Fed”) entered into an agreement with The Bank of Nova Scotia and its New York agency (collectively, the “Bank”), obligating the Bank to submit revised compliance programs for several key areas, including BSA/AML, Customer Due Diligence, and Suspicious Activity Monitoring and Reporting.… Read More