The Office of the Comptroller of the Currency has announced 15 anti-money laundering enforcement actions so far this year, triple its total for all of 2017 and increased penalties from $1 million to $137.9 million.

The ramped-up enforcement — against institutions including U.S. Bank and Rabobank — show that Bank Secrecy Act/anti-money laundering compliance remains a top priority as the OCC has transitioned to new leadership under the Trump administration.

Bank secrecy and anti-money laundering deficiencies are regarded by the OCC to be "one of the most significant risks facing banks today," Peter Hardy, a partner at Ballard Spahr in Philadelphia, told Bloomberg Law. This year's uptick in enforcement activity "could reflect the OCC reacting to those concerns with concrete action," he said.

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