Anti-Money Laundering compliance programs
Anti-money laundering compliance in Healthcare and Life Sciences sits at an uncomfortable intersection: the Financial Crimes Enforcement Network's Customer Due Diligence rule applies directly to covered financial institutions processing healthcare payments, while the U.S. Department of Justice has used Bank Secrecy Act theories in prosecutions touching pharmaceutical distribution and clinical trial funding flows. State-level enforcement, particularly from the New York Department of Financial Services, adds a second compliance layer for health system treasury and revenue cycle operations that many programs have not fully mapped.
Watch
- FinCEN's proposed beneficial ownership reporting rules and their reach into health system subsidiaries
- DOJ Bank Secrecy Act prosecutions involving pharmaceutical distributors: pattern worth tracking
- NYDFS Part 504 transaction monitoring requirements applied to health-adjacent financial entities
- Gaps between AML program certifications and actual vendor payment screening in revenue cycle
Recent material activity in Healthcare & Life Sciences
Active monitoring in place across Healthcare & Life Sciences. Material developments related to anti-money laundering compliance programs will appear here as they are published.