NOTE TO FINCEN; PUNISH THE DIRECTORS, NOT THE COMPLIANCE OFFICER, PLEASE

Rumors abound that FinCEN is intent upon levying a civil penalty, in the millions of dollars, upon a former ranking compliance officer, who served at a money service business that has a number of money laundering violations. Remember your chain of command, ladies and gentlemen. It is the directors of any NBFI that bear the responsibility for major AML/CFT failures. They represent the most senior management, and the buck certainly stops there.

Please do not let me see that some compliance officer, widely known for his innovations in compliance, is being made the sacrificial goat for the directors, who, at the end of the day, should take the hit. Remember, when there are compliance failures, and the compliance staff is good at their jobs, that means that their suggestions were trumped by the lure of profit, and their suggestions were vetoed by the directors. Don't blame the gatekeeper when the manager orders the sheep to be let out. fine and indict the directors, if you have any sense of justice and fairness.