Should a financial institution be held fully responsible for unknowingly supporting terrorist financing when their compliance program is up to date?
The answer to this question, which was posted on a LinkedIn anti-money laundering blog, would seem obvious: a robust, proactive compliance program should serve as a shield against civil or criminal enforcement actions. But it does not. BPN Paribas, which had a robust compliance program, last year paid nearly nine billion dollars in criminal and civil penalties. In a suit brought under the Anti-Terrorism Act, Arab Bank PLC's compliance program was not even admissible as a defense to a civil action. So, the answer to this question is clear: an up-to-date compliance program does not shield a financial institution from liability.
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