As you’re all well aware, earlier this year, Ripple was the subject of the first digital currency enforcement action leveled by regulators for BSA/AML violations. FinCEN and the U.S. Attorney’s Office assessed $750,000 in fines, as well as (even more costly) “enhanced remedial measures”. The company further agreed to biannual compliance audits of its BSA/AML program, and the aforementioned enhancements, through 2020.
Since the enforcement action, Ripple has reportedly gone on a hiring spree, retaining compliance specialists, AML analysts, and regulatory relations personnel. The company also introduced a new BSA Compliance Officer in February, prior to the settlement though likely during the regulatory exam process. As it so often does, the cost of the regulatory fine will ultimately pale in comparison to the final price tag for Ripple’s remedial efforts. Moreover, being under an enforcement action means your company operates and innovates on the regulator’s schedule, not yours.