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Compliance & Ethics

Italy Opens Investigation Into Suno Over Unfair Consumer Terms

Italy’s competition authority has opened an investigation into Suno, putting the generative AI music company’s Terms of Service under scrutiny over provisions that appear to give the company considerable freedom over its users while sharply limiting what those users can do in return.

DNB Fines Modulr Finance Over Serious Anti-Money Laundering Failures

Very large sums were arriving without enough being known about where the money had come from. Some transactions carried clear signs of elevated risk. Modulr Finance sometimes investigated them only minimally, and sometimes not at all. Those findings form part of the case that led De Nederlandsche Bank to fine the electronic money institution €722,160 for serious shortcomings in its anti-money laundering controls.

FinCEN Pulls Back Two Proposed Digital Asset Rules

The Financial Crimes Enforcement Network has abandoned two proposed rules that would have tightened federal requirements around certain digital asset transactions, including those involving unhosted wallets and convertible virtual currency mixing.

Signal Diagnostics to Pay $20.5 Million Over Unreturned COVID-19 Overpayments

Signal Diagnostics found the problem itself. In January 2022, the clinical laboratory began an internal audit of claims it had submitted to a federal program that reimbursed healthcare providers for treating and testing uninsured patients during the COVID-19 pandemic. What the company found was not trivial. Some of the people it had billed as uninsured had health insurance.

Austria’s Supreme Cartel Court Raises Kiesel Fine Tenfold Over Two Illegal Mergers

Austria’s Supreme Cartel Court has increased the fine against German construction machinery company Kiesel from €240,000 to €2.4 million for implementing two mergers before the law permitted it to do so, turning what had been a relatively modest penalty into one intended, quite deliberately, to be felt.

AUSTRAC Sets Out Five Habits for Stronger AML Compliance

AUSTRAC has reduced good anti-money laundering compliance to five pieces of advice, and none of them is particularly exotic. Know which obligations apply to the business. Keep the regulator informed when basic company details change. Revisit the risks as the business changes. Make sure reports contain information somebody can actually use. Keep records good enough to explain the decisions made along the way.

Finnish Financial Regulator Updates Penalty Framework With Greater Credit for Early Cooperation

Finland’s Financial Supervisory Authority (FIN-FSA) has published updated principles on October 1 for determining the size of penalty payments and administrative fines. The principles themselves are not new. The authority published an earlier version in 2022, and the latest changes largely put greater precision around practices that have since become established.