The Largest Broker-Dealer AML Penalty Ever - UBS, FinCEN Leadership Changes, and the Future of SAR Reporting

This week on This Week in AML, John Byrne and Elliot Berman examine FinCEN's record-setting $125 million enforcement action against UBS, the largest civil money penalty ever imposed against a broker-dealer for Bank Secrecy Act violations. They discuss what made the case significant, the consequences of repeated compliance failures, and the lessons financial institutions should take from the enforcement action.

The conversation also covers FinCEN Director Andrea Gacki's departure for Citibank and what the appointment of Acting Director Jenna Casanova could mean for future enforcement priorities.

John and Elliot then explore Senator Ron Wyden's report on financial institutions' handling of Jeffrey Epstein-related accounts, including proposed changes to suspicious activity reporting requirements and concerns about SAR confidentiality. They also review Capital One's defense of account closures tied to AML obligations and the broader debate surrounding claims of "debanking."

Internationally, the hosts discuss the FCA's planned overhaul of transaction reporting requirements in the UK, ongoing challenges in accessing beneficial ownership registries across the European Union, and Transparency International's push for stronger global anti-corruption measures.