Working in concert with in-house counsel, members of the CRA team led a review of a Swiss bank’s existing compliance policies, protocols and procedures for their private bank. The review was focused on revamping the bank’s risk-rating approach in certain geographies, and insuring client on-boarding procedures and vetting were consistent with the recommendations from US regulatory authorities as well as in line with peer baking institutions’ policies. The team’s recommendations were adapted by the bank, briefed to the SEC and Federal Reserve, and applied across multiple geographies.
DOJ launches pilot program to enhance voluntary self-disclosure and combat white-collar crime
In April 2024, the US Department of Justice (DOJ) Criminal Division released its Pilot Program on Voluntary Self-Disclosures for Individuals to help detect and...