Following much criticism from federal examiners in 2010–2011, financial institutions have had to develop more effective Bank Secrecy Act and anti-money laundering (AML) compliance programs to address heightened regulation and enforcement. Meeting this challenge involves implementing business process improvements, recruiting additional staff and adopting enterprise-wide...

In many criminal investigations, evidence of criminally derived proceeds becomes apparent to investigators, but subsequent comingling with legitimately obtained wealth makes future financial transactions more ambiguous and difficult to charge as substantive offenses. The following situation will illustrate practical methods of obtaining evidence to support...