COMPLIANCE DIRECTORS; DO NOT SEND YOUR STAFF TO FLORIDA EVENTS THIS FALL

If you are a director of compliance who is considering sending frontline compliance staff to any of the AML/CFT conferences in South Florida this fall, you need to think again. The state's far-right anti-immigration and minority governor and legislature have enacted a law that greatly increases not only the risks to your staff, but to you as well. Do you have Latino staff members? Please read on.

First of all,you must, immediately, secure written evidence from anyone you might consider sending to a Florida conference of their legal status. That means a copy of their enhanced due diligence driver's license, if you live in a state where one must be a citizen to hold a license. If not, a copy of the staff members' legal residency ID. This is because there are now serious restrictions upon individuals who are undocumented regarding travel. Their out-of-state driver's licenses are no longer valid, meaning they are subject to arrest and detention. do you really want a call at 3 AM from some local jail, begging you to assist in obtaining a bond? we doubt it. A Latino advocacy is publicly warning of the consequences of being in Florida as an undocumented person; take this seriously, please.

Next, you personally can be liable in Florida if you facilitate travel of an undocumented (illegal) alien. While it is not yet clear what you might be subject to, this kind of exposure to risk must be avoided at all costs. Finally, due to new policies in Florida, the NAACP has warned African-Americans not to travel to Florida, under any circumstances.

Therefore, secure proof of citizenship or legal residency from ALL your staff members now, no matter what they appear to be. Then, conduct a risk assessment on anyone who might be going to Florida, make sure they have (1) proof in hand on their person, and (2) information regarding a bail bondsman you have made available to them to contact, in case they are detained anyway.

You are advised to consult with legal counsel on this issue, so make that individual aware of the potential risk to your staff, and possible preparation in the event there is trouble. You may also want to consider avoiding those Florida conferences altogether. Protect your staff, because jail and possible deportation is no joke.