Money Laundering Bulletin
Deferred prosecution – preferred option
Late to the party perhaps with beneficial ownership due diligence obligations – the FinCEN final rule takes effect on 11 May
– the US led the way with deferred prosecution agreements (DPAs), an approach to resolution, beyond regulatory enforcement
but stopping short of full criminal sanction, that is proving increasingly popular with other jurisdictions. Sara Lewis and
Keith Nuthall track the trend.