This article was published on KYC360.com on March 4, 2020

2019 was the year of clarifying guidance from law enforcement, regulators, and anti-financial crime organizations, even if the effects of new expectations haven’t quite appeared in the form of increased enforcement actions. Nonetheless, it is quite likely that the punitive tail of non-compliance may start to manifest in 2020 and beyond.

Regulatory trends comprise of a mixed bag of disciplinary statistics in recent years. Enforcement against entities supervised by the Federal Reserve dropped to the fifties in 2019 from an average of 87 per year the previous three years. Civil Monetary Penalties and Cease & Desist Orders issued by the Office of the Comptroller of the Currency (OCC) have numbered 76, 73, 61, and 45 since 2016. Conversely, the Office of Foreign Assets Control (OFAC) civil penalties peaked at 26 in 2019 since bottoming out at nine in 2016. And while predicting what any agency may focus its resources on in any given year is a dubious prospect at best, it is certain that the direction provided by Department of Justice (DOJ), OFAC, the Wolfsberg Group, and others last year will set heightened standards and expectations when it comes to preventing, detecting, and reporting financial crime.

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