FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more
3/15/2024
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
CDD ,
CFIUS ,
China ,
Customer Identification Program (CIP) ,
Due Diligence ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
FinCEN ,
Infrastructure ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investors ,
No-Action Letters ,
Popular ,
Private Funds ,
Proposed Rules ,
Risk Assessment ,
Russia ,
Securities and Exchange Commission (SEC) ,
SIFMA ,
Suspicious Activity Reports (SARs) ,
Technology Sector
Will 2022 Be the Year of Supply Chain Ethics?
Effective June 21, 2022, in an effort to address forced labor concerns, U.S. law will broadly prohibit imports of products from China’s Xinjiang Uyghur Autonomous Region...more
1/19/2022
/ China ,
Compliance ,
Customs and Border Protection ,
Due Diligence ,
Enforcement ,
Environmental Social & Governance (ESG) ,
Ethics ,
Forced Labor ,
Human Rights ,
Imports ,
Sanctions ,
Supply Chain ,
Tariff Act of 1930 ,
Uyghur Forced Labor Prevention Act (UFLPA) ,
Withhold Release Orders (WROs)
As the Biden Administration commits to crack down on corruption, recent enforcement actions show the DOJ continues a longstanding trend of relying on AML laws and other alternate statutes to prosecute corruption cases, with...more
7/14/2021
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Compliance ,
Corruption ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Popular ,
RICO ,
Travel Act ,
Wire Fraud
BitMEX, a Seychelles-based centralized exchange for trading derivatives on bitcoin, ether and litecoin, and certain of its executives have been charged with a number of violations under the U.S. Commodity Exchange Act (CEA),...more
10/8/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
CFTC ,
Commodity Exchange Act (CEA) ,
Department of Justice (DOJ) ,
Digital Assets ,
Due Diligence ,
Ether ,
Futures Commission Merchants (FCMs) ,
Geo-Blocking ,
SEFs ,
Trading Platforms ,
U.S. Customs
As it targets terrorist groups and their finances, the U.S. Government announces potent secondary sanctions that can impede correspondent banking relationships of non-U.S. banks.
A new U.S. Executive Order updates the...more
9/12/2019
/ Anti-Money Laundering ,
Due Diligence ,
Entity List ,
Executive Orders ,
Financial Institutions ,
Foreign Banks ,
Non-Bank Lenders ,
SDN List ,
Terrorism Funding ,
Terrorist Financing Regulations ,
U.S. Treasury
On 16 March 2017, the European Parliament approved a draft EU regulation intended to ensure that trade in certain minerals and metals from high-risk or warn-torn areas does not fund conflict and human rights abuses. The...more
On May 11, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury, published its final rule addressing Customer Due Diligence Requirements for Financial Institutions (CDD Rule)....more
On August 13, 2014, the Office of Foreign Assets Control (OFAC) issued new guidance on ownership/control for determining blocked parties. This represented the first significant update on this topic since February 14, 2008,...more