When are Anti-Money Laundering Program Deficiencies a Crime?

In early 2018, the Department of Justice (“DOJ”) brought two criminal actions relating to Anti-Money Laundering (“AML”) program deficiencies. This article examines the criminal actions brought against Rabobank National Association (“Rabobank”) and US Bank National Association and US Bancorp (collectively “US Bank”) by the DOJ relating to their AML programs and the reasons why the violations rose to the level of criminal charges.

To read the entire article on the Corporate Compliance Insights website, click here.