Securities and Exchange Commission (“SEC”) Enforcement Division Director Andrew Ceresney, recently drew attention when he announced that the SEC intends to include among its enforcement priorities compliance with the Bank Secrecy Act (the “BSA”). Ceresney’s comments, made during SIFMA’s 2015 Anti-Money Laundering and Financial Crimes Conference, focused on broker-dealers and the SEC’s concern that broker-dealers have not implemented adequate anti-money laundering (“AML”) programs to comply with the BSA’s reporting and recordkeeping requirements. BSA enforcement actions against financial institutions – and the significant penalties and forfeitures associated with those actions – have garnered significant press in the past few years. Broker-dealers have historically avoided much of this scrutiny, as the SEC has generally viewed AML lapses as attendant to other violations. Those days, however, appear to be numbered. This issue has received recent attention by Financial Industry Regulatory Authority (“FINRA”) enforcement, as well as by the SEC’s Office of Compliance Inspections and Examinations.