NCJ Number
147590
Journal
Criminal Justice Volume: 8 Issue: 4 Dated: (Winter 1994) Pages: 9-12,54-56
Date Published
1994
Length
7 pages
Annotation
Anti-money laundering laws are discussed.
Abstract
This article analyzes and briefly summarizes recent legislative action and judicial decisions that impose greater burdens and higher risks of criminal liability on financial institutions for involvement in money laundering activities. Under the Annunzio-Wylie Act, Congress empowered the Secretary of the Treasury to require financial institutions to establish and implement anti-money laundering programs. These programs should be designed to teach employees about situations that require further investigation and to establish procedures to comply with the legal obligations. At a minimum, such a program must include development of internal policies, procedures, and controls; designation of a compliance officer; implementation of an ongoing employee-training program; and testing of the program by independent audit. It should be made clear to personnel that the program was established to ensure compliance with money laundering and bank secrecy laws and that bank personnel will be reprimanded or discharged for not following these internal compliance procedures. A brief discussion of each of these elements is included.