Himamauli Das
NYU Law’s Program on Corporate Compliance and Enforcement (PCCE)
March 25, 2022
Good morning and thank you for inviting me to be a part of your discussions this year. I want to start by thanking Jennifer Arlen and the staff at NYU’s Program on Corporate Compliance and Enforcement for focusing on the effectiveness of corporate compliance programs.
Current events often make clear the importance of compliance programs that are well designed and effective in preventing bad actors from exploiting the financial system. As the pandemic began to unfold in 2020, FinCEN pivoted its efforts to focus on the effects that COVID-19 was having on a range of illicit finance threats around the world. We issued guidance and advisories to advise financial institutions of trends that we were seeing related to COVID-19 medical fraud, imposter scams, cyber-enabled crime, and the defrauding of the unemployment insurance system. And, we assisted law enforcement and financial institutions in the recovery of stolen funds via fraud and other COVID-19 related crimes.