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Implementation of the AMLA and the CTA by Financial Institutions: A Podcast

By Peter D. Hardy & Terence M. Grugan on October 20, 2022
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With Guest Speaker Matthew Haslinger of M&T Bank

We are extremely pleased to offer a podcast (here) on the legal and logistical issues facing financial institutions as they implement the regulations issued by the Financial Crimes Enforcement Network (FinCEN) pursuant to the Anti-Money Laundering Act of 2020 (AMLA) and the Corporate Transparency Act (CTA), and as they try to anticipate future related regulations.

We are very fortunate to have Matthew Haslinger as our guest speaker. Mr. Haslinger serves as the Chief BSA/AML/OFAC Officer for M&T Bank.  He began his career as a federal prosecutor in the Bank Integrity Unit of the U.S. Department of Justice’s Money Laundering and Asset Recovery Section, where he investigated and prosecuted complex national and international money laundering and sanctions-related matters.  Mr. Haslinger then moved to M&T Bank, where he initially headed the Financial Investigations Unit and was responsible for day-to-day operations and strategic decision-making relating to enterprise-wide transaction monitoring, customer investigations and suspicious activity report filing for the bank.  In July 2020, he became the Chief BSA/AML Officer.  In this role, Mr. Haslinger is now responsible for oversight, implementation, and strategic direction of the enterprise-wide programs for Bank Secrecy Act (BSA), Anti-Money Laundering (AML) and Governmental Sanctions compliance.

In this podcast, we dive into the historic changes made by the AMLA and the CTA. After reviewing how the AMLA expands the BSA’s goals, we look at some of the AMLA provisions which have the most impact on BSA compliance, including the AMLA’s emphasis on information sharing, FinCEN’s “national priorities” and the value of threat pattern and trend information to bank compliance efforts, and the AMLA’s expansion of the U.S. government’s authority to subpoena information from foreign financial institutions that maintain correspondent banking relationships with U.S. banks. We also review the CTA’s new beneficial ownership reporting requirements and discuss how they may interact with existing customer due diligence (CDD) requirements and the need to align CTA and CDD regulations.

This podcast is the latest episode in Ballard Spahr’s Consumer Financial Monitor Podcast series — a weekly podcast focusing on the issues that matter most, from new product development and emerging technologies to regulatory compliance and enforcement and the ramifications of private litigation. We hope that you enjoy the podcast.

If you would like to remain updated on these issues, please click here to subscribe to Money Laundering Watch. To learn more about Ballard Spahr’s Anti-Money Laundering Team, please click here.  To visit Ballard Spahr’s Consumer Financial Monitor blog, please click here.

Peter D. Hardy

hardyp@ballardspahr.com | 215.864.8838 | view full bio

Peter is a national thought leader on money laundering, tax fraud, and other financial crime. He is the author of Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation, a comprehensive legal treatise published by Bloomberg…

hardyp@ballardspahr.com | 215.864.8838 | view full bio

Peter is a national thought leader on money laundering, tax fraud, and other financial crime. He is the author of Criminal Tax, Money Laundering, and Bank Secrecy Act Litigation, a comprehensive legal treatise published by Bloomberg BNA.  Peter co-chairs the Practising Law Institute’s Anti-Money Laundering program, and serves on the Steering Committee for the Cambridge Forum on Sanctions & AML Compliance

He advises corporations and individuals from many industries against allegations of misconduct ranging from money laundering, tax fraud, mortgage fraud and lending law violations, securities fraud, and public corruption.  He also advises on compliance with the Bank Secrecy Act and Anti-Money Laundering requirements.  Peter handles complex litigation involving allegations of fraud or other misconduct.

Peter spent more than a decade as a federal prosecutor before entering private practice, serving as an Assistant U.S. Attorney in Philadelphia working on financial crime cases. He was a trial attorney for the Criminal Section of the Department of Justice’s Tax Division in Washington, D.C.

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Terence M. Grugan

grugant@ballardspahr.com | 215.864.8320 | view full bio

Terence’s practice focuses on representing clients involved in criminal, regulatory, and administrative investigations and litigation, and in civil litigation matters involving the federal securities laws and other allegations of fraudulent business practices. He represents…

grugant@ballardspahr.com | 215.864.8320 | view full bio

Terence’s practice focuses on representing clients involved in criminal, regulatory, and administrative investigations and litigation, and in civil litigation matters involving the federal securities laws and other allegations of fraudulent business practices. He represents financial institution clients in matters implicating their practices under the BSA and related AML laws, including compliance program advice, internal investigations, regulatory examinations, and related civil litigation.

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  • Posted in:
    Corporate Compliance, Corporate Finance
  • Blog:
    Money Laundering Watch
  • Organization:
    Ballard Spahr LLP
  • Article: View Original Source

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