In this article, Ann Sultan and Maryna Kavaleuskaya* reviewed three themes in enforcement of anti-money laundering (AML) compliance program deficiencies in 2018, including enforcement agencies' emphasis on the adequacy of AML programs, emphasis on companies' integrity in interactions with the U.S. government, and aggressive action against companies with prior AML compliance issues. "U.S. authorities continue to demand that financial and non-financial institutions have AML compliance programmes that are tailored to the risks they face," the authors wrote.

*Former Miller & Chevalier attorney