A recent Reed Smith Client Alert discusses a June 2015 speech by Stephanie Brooker, Associate Director for Enforcement at the Financial Crimes Enforcement Network (“FinCEN”). Although Ms. Brooker’s comments were specifically directed at the casino and card club industries, she discussed six “core principles” that have and will continue to guide FinCEN’s BSA/AML enforcement activities against all financial institutions, including banks and mortgage lenders. In particular, the alert discusses FinCEN’s focus on transparency, supervisory goodwill, recidivism, targeting individual directors, officers, and other employees of regulated entities, developing a remedial framework to correct prior deficiencies, and accountability. As to this last point, the alert discusses the extent to which FinCEN – and other regulators (e.g., the OCC) – have required respondents to actually admit liability for the charged violations, rather than merely “neither admit nor deny” as has been the historical practice. Additionally, the alert discusses FinCEN’s expectations that regulated entities develop and exhibit a “culture of compliance.” While insured depository institutions will likely be familiar with this mantra, which has been sounded by federal bank regulators for decades, other regulated entities, such as mortgage lenders, money services businesses, and casinos, might not be accustomed to FinCEN’s expectations. To read the alert in full, click here.