ederal enforcement of anti-money laundering compliance has been picking up. In 2009, there were two fines against two banks while, in 2010, there were seven fines against five banks. Of greater note, as recently pointed out on Mon-eyLaundering.com, the size of the BSA-related fines went from $5 million in 2010 to $660 million thus far in 2011. And BSA fines represent the majority of fines on banks now. In addition to these negative trends, consider that late last year, Assistant Attorney General Lanny Breuer announced the creation of a new unit within the Criminal Division of the Department of Justice to focus on "financial institutions, including their officers, managers, and employees, when their actions violate the law." In announcing this new unit, Breuer warned: "Financial institutions simply cannot cut corners on compliance: having a compliance program that works is worth it."
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