Abstract
In the 1980s, commercial businesses began coming under the scrutiny of criminal investigators and prosecutors who are using the criminal enforcement process as a means of regulating business conduct. No sector of US business faces greater exposure to increased criminal enforcement activity than the financial services industry. Two recently enacted statutes are used in criminal enforcement: the Financial Institutions Reform, Recovery, and Enforcement Act of 1989 and the Comprehensive Thrift and Bank Fraud Prosecution and Taxpayer Recovery Act of 1990. A number of scenarios are presented to illustrate some of the potential pitfalls faced by banks in the course of routine transactions. It is important for banks to establish and to monitor closely a compliance program designed to deter and detect any abuses under both the Money Laundering Control Act of 1986 and the Bank Secrecy Act.