Davis Polk partner Dan Stipano was quoted in Thomson Reuters Regulatory Intelligence and MoneyLaundering.com from a panel at the ACAMS AML & Financial Crime Conference, during which he discussed the DOJ potentially requiring compliance officers to sign off on plans by their employers to eliminate anti-money laundering lapses. Dan noted during the panel that this kind of certification measure could lead to unintended consequences and “if I was advising someone in that position, number one I’d say, ‘Don’t put pen to paper unless you have absolute certainty that everything you are attesting to is accurate.’”

“US Justice Department Plans Compliance Certification Program,” MoneyLaundering.com (March 22, 2022) (subscription required)

“U.S. DOJ ratchets up compliance push by floating certification requirement in settlements,“ Thomson Reuters Regulatory Intelligence (March 24, 2022) (subscription required)

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