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This document appears to be page 25 of a compliance manual or guide produced by the consulting firm Protiviti. It outlines the key components of an Anti-Money Laundering (AML) program, including risk assessments, customer acceptance (KYC), suspicious activity monitoring (SARs), and sanctions programs (OFAC). It also details how technology can support these AML functions, such as calculating risk ratings and searching against high-risk lists (PEPs). The document bears a 'HOUSE_OVERSIGHT' Bates stamp, indicating it was produced as evidence in a congressional investigation, likely related to financial institutions involved with Jeffrey Epstein, though Epstein is not named on this specific page.
This document is page 23 of a report by Protiviti, likely produced for the House Oversight Committee, detailing common deficiencies in Anti-Money Laundering (AML) compliance programs. It cites specific enforcement actions and financial penalties against E*TRADE (2008-2009) and Sigue Corporation (2008) for failures in suspicious activity monitoring and reporting. The text outlines systemic violations such as failure to file SARs, lack of independent testing, and inadequate training, serving as a reference for regulatory expectations.
This document appears to be page 22 of a report by the consulting firm Protiviti, prepared for the House Oversight Committee (indicated by the Bates stamp HOUSE_OVERSIGHT_024128). The text outlines historical regulatory failures regarding Anti-Money Laundering (AML) and the Bank Secrecy Act (BSA) at HSBC and Citibank. It details Cease and Desist orders issued by the Federal Reserve and the OCC in 2010 and 2012, citing deficiencies in monitoring suspicious activity, wire transfers, and foreign correspondent banking. While part of an investigation file often associated with Epstein (likely the Deutsche Bank investigation), this specific page focuses on the regulatory history of other major banks as context.
This document is page 20 of a regulatory guide produced by Protiviti, stamped with a House Oversight Bates number. It outlines various enforcement actions available to U.S. regulators regarding Anti-Money Laundering (AML) compliance, ranging from Commitment Letters and MOUs to Civil Money Penalties and the so-called 'Death Penalty' (charter revocation). It also defines the enforcement authority of FinCEN and mentions Deferred Prosecution Agreements.
This document is page 18 of a report produced by the consulting firm Protiviti, likely part of a production to the House Oversight Committee (indicated by the Bates stamp HOUSE_OVERSIGHT_024124). The text provides a high-level overview of the Financial Crimes Enforcement Network (FinCEN), detailing its history, mission, and role in Anti-Money Laundering (AML) regulation. It outlines FinCEN's initiatives, including the BSAAG and FFETF, and describes various information-sharing systems like the BSA E-Filing System and Egmont Secure Web.
Page 17 of a report produced by Protiviti, bearing a House Oversight Committee bates stamp. The document is a reference manual regarding Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. It outlines various government strategies and reports, including the Money Laundering Threat Assessment (MLTA), the National Money Laundering Strategy (NMLS) of 2007, and State Department reports on narcotics (INCSR) and terrorism. While part of a production likely related to Epstein's financial enablers, this specific page discusses general regulatory frameworks rather than specific transactions.
This document is page 15 of a report produced by the consulting firm Protiviti, bearing a House Oversight Committee Bates stamp. It outlines the U.S. federal agencies responsible for combating money laundering and terrorist financing (including specific offices within Treasury, DOJ, and the State Department) and details key regulatory publications such as the FFIEC Bank Secrecy Act/AML Examination Handbook.
This document is page 14 of a report produced by the consulting firm Protiviti, submitted to the House Oversight Committee (Bates: HOUSE_OVERSIGHT_024120). It serves as an educational guide defining key US financial regulatory bodies (FFIEC, SEC, CFTC, FINRA, etc.) and their specific roles in Anti-Money Laundering (AML) and compliance. While part of a larger discovery production likely related to financial investigations, this specific page contains no direct references to Jeffrey Epstein, his associates, or specific illicit transactions; it outlines the regulatory framework under which financial institutions operate.
This document appears to be page 12 of a compliance guide or white paper produced by Protiviti, which was included in a House Oversight Committee production (Bates: HOUSE_OVERSIGHT_024118). The text provides a historical overview of US Anti-Money Laundering (AML) legislation from 1992 to 2004, explains the role of the Office of Foreign Assets Control (OFAC), discusses metrics for measuring AML regime effectiveness, and notes that the US is not in full compliance with international FATF recommendations regarding beneficial ownership.
This document is a page from a compliance or training manual produced by Protiviti, likely submitted as evidence to the House Oversight Committee. It provides an overview of U.S. Anti-Money Laundering (AML) laws and regulations, distinguishing between money laundering and terrorist financing. It details key legislation including the Bank Secrecy Act of 1970, the USA PATRIOT Act of 2001, and the Money Laundering Control Act of 1986, outlining penalties and compliance requirements for financial institutions.
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