When a penalty, rule or advisory changes the risk, Forward Global sends clients a short alert: what happened, why it matters and the questions directors and executives should ask. Recent examples are below. The latest is open to all. Subscribers receive the archive by email at once, and each new alert as it is issued.
FinCEN flagged more than $8 billion in suspicious payments that money services businesses sent abroad on their foreign agents’ instructions. The legal exposure, the enforcement record and the two decisions boards should take now.
The consent order names no Mexican institution, but its core findings describe Mexican exposure. Why the consequences will arrive through U.S. correspondents, and what they will ask.
A risk assessment built around the deposit book, not the card business that dominates it. What audit committees should test now.
Money services businesses filed 97 percent of the reports; banks filed 3 percent and reported 61 percent of the money. Why programs calibrated to published volumes miss the risk.
A missed remediation deadline, and silence about it, turned technical defects into the largest anti-money laundering penalty ever imposed on a broker-dealer.
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