COMPLIANCE OFFICERS MUST PLAY THE LONG GAME, IF THEY WANT TO PROTECT THEMSELVES, AND THEIR BANK, WHEN THE PENDULUM SWINGS BACK ON ENFORCEMENT

Consider this article a totally non-political reality check; professional guidance during a period of governance that may later be judged harshly. Compliance officer, protect thyself.

If you are one of those people feeling relieved, as the present administration stops enforcing FCPA violations on American citizens, and relaxes AML regulations across the board, think again. Enforcement will most likely swing back under the next US government, and you and your bank may be left holding the bag on what you thought was safe, but has now become the subject of regulators and law enforcement making an example of. In short, expect a tightening of regulatory action in the not so distant future, and don't get caught out in the cold.

The Statute of limitations will not have run out in 2029 on criminal violations arising during the next three years, and our conspiracy statutes will fit the gap on those that do. My advice is to continue to operate your AML/CFT compliance program under 2024 rules; to do otherwise invites a future visit from newly zealous regulators or law enforcement agencies, operating under zero tolerance rules; Govern yours