Moody’s Talks: Risk Reframed

AFC enforcement in the USA: 2022 retrospective


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The steadfast enforcement of anti-financial crime regulations in the US often leads to severe financial consequences for offenders. Jill DeWitt, Moody’s KYC Industry Practice Lead for Financial Crime and Due Diligence in the Americas, profiled some US companies that were fined in 2022. While fines ranged from thousands to hundreds of millions of dollars, a few key themes emerged across the board. In this episode, Jill guides us through some observations, including:

  • Business growth vs. Compliance growth
  • Staffing and training complications
  • Suspicious Activity Report (SAR) filings and backlogs in CDD
  • Screening issues
  • General program failures

For additional information, check out the resources below that were highlighted in this episode:

  • Financial Crimes Enforcement Network (FinCEN)
  • US Department of the Treasury Office of Foreign Assets Control (OFAC)
  • Next generation sanctions screening against IP addresses blog
  • KYC - Driving customer loyalty, advocacy, and business growth blog

If you are looking to take your due diligence program to the next level, please get in touch – we’d love to hear from you. 


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