Outside Counsel

Broker-Dealer Compliance in Era of Regulatory Pressures

, New York Law Journal

Robert C. Gottlieb and Derrelle M. Janey discuss key points from the Brown Brothers Harriman case, where the private bank was fined a record $8 million for anti-money laundering compliance failures: compliance programs must be intensely active, living organisms that constantly "monitor," continuously "investigate," "ensure" that issues are reported and, once reported, have an adequate protocol for "updating" on the activity at issue.

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