Anti-money laundering and sanctions compliance challenges for custody services

US federal and state agencies are bringing more enforcement actions, and obtaining larger penalties than ever, for anti-money laundering (AML) and financial sanctions violations. US AML and sanctions obligations extend to all bank and broker– dealer operations, including custody operations. This paper describes the AML and sanctions frameworks applicable to bank and broker–dealer custody operations, and discusses three key compliance risks for those activities: accounts held for financial intermediaries, foreign financial institutions and microcap securities.