Does the punishment fit the crime?

Describes anti‐money laundering statutes within the US federal criminal code. Introduces the USA’s Bank Secrecy Act (BSA), a record‐keeping and reporting statute that also requires financial institutions to implement comprehensive anti‐money laundering programmes; its enforcement authority is generally exercised through the Financial Crime Enforcement Network (FinCEN). Outlines the bank regulatory authority, administrative sanctions, civil money penalties, and the “death penalty”, which is termination of a national bank’s franchise. Discusses recent enforcement actions by FinCEN, the Department of Justice, and Federal banking agencies. Concludes that the apparent trend towards more substantial fines and other sanctions for BSA violations will probably accelerate for various reasons.