Failures in implementing AML Transaction Monitoring increasingly have real world consequences, as the US government continues to crack down on money laundering. A lack of tolerance for low quality AML measures is seeing more and more cases of prosecution under the Bank Secrecy Act. One of the most recent involves two co-defendants named in an indictment from March 2021 who, in September this year, pleaded guilty to "failing to maintain an effective anti-money laundering program." As a result of the failure, the two defendants, Hanan Ofer and Gyanendra Asre, are named in charges involving $1 billion in "high risk" transfers. The pair are accused of having run an unlicensed money transmitter business, targeting investors less sophisticated than they were offering to operate High Risk Business Lines on their behalf. The big issue is that both the defendants had the knowledge and experience to operate those business lines - and provide the necessary AML Transaction Monitoring and oversight for them.