On August 1, 2024, the Department of Justice launched its Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). Under this 3-year initiative managed by DOJ’s Criminal Division, a whistleblower may be eligible...more
8/12/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Department of Justice (DOJ) ,
Financial Institutions ,
Financial Services Industry ,
Money Laundering ,
Pilot Programs ,
Terrorist Financing Regulations ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
FinCEN’s recent preliminary rulemaking aims to enhance and modernize regulations with requirements and priorities that affect a broad range of “financial institutions” across industries—but lacks concrete guidance on...more
7/26/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Chevron Deference ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Popular ,
Regulatory Agenda ,
Risk Assessment ,
Terrorist Financing Regulations
On June 14, 2024, President Biden declared June 15th World Elder Abuse Awareness Day. In honor of the day, the Financial Crimes Enforcement Network (FinCEN) reminded financial institutions (FIs) to remain vigilant in...more
6/24/2024
/ Bank Secrecy Act ,
BSA/AML ,
Consumer Financial Products ,
Elder Abuse ,
Exploitation ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Reporting Requirements ,
Scams ,
Suspicious Activity Reports (SARs) ,
Vulnerability Assessments
The Financial Crimes Enforcement Network (“FinCEN”) recently issued a Financial Trend Analysis (“Analysis”) focusing on patterns and trends identified in Bank Secrecy Act (“BSA”) data linked to Elder Financial Exploitation...more
5/2/2024
/ Bank Secrecy Act ,
BSA/AML ,
Elder Abuse ,
Exploitation ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
New Guidance ,
Popular ,
Scams ,
Suspicious Activity Reports (SARs)
On March 28, 2024, the Financial Crimes Enforcement Network (FinCEN), in consultation with the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, the National Credit Union Administration,...more
Following Russia’s invasion of Ukraine, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert and a supplemental alert (the...more
9/18/2023
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Suspicious Activity Reports (SARs)
Summary -
The Department of Justice’s creation of two new leadership positions within the National Security Division (NSD) sends another strong signal to the private sector that federal law enforcement is pouring resources...more
Summary -
On September 30, 2022, the Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of Treasury, issued its final rule, Beneficial Ownership Information Reporting Requirements (Final Rule),...more
Second Post in a Two-Post Series on the CTA Implementing Regulations -
As we just blogged, the Financial Crimes Enforcement Network (“FinCEN”) has issued a final rule (“Final Rule”) regarding the beneficial ownership...more
First Post in a Two-Post Series on the CTA Implementing Regulations -
On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued its final rule, Beneficial Ownership Information Reporting...more
As we initially blogged, the Financial Crimes Enforcement Network (“FinCEN”) issued on December 7 a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership (“BO”) reporting requirements of the Corporate...more
Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership reporting requirements of the Corporate Transparency Act (“CTA”), which...more
The Financial Crimes Enforcement Network (“FinCEN”) recently complied with two important deadlines under the Anti-Money Laundering Act (“AML Act”) — issuing national priorities for AML and countering the financing of...more
Much has occurred in the last two months regarding the relationship between financial institutions and Marijuana-Related Businesses, or MRBs. In this post, we discuss three major developments, all of which share a complex...more
In its most recent Marijuana Banking Update, the Financial Crimes Enforcement Network (FinCEN) stated that the decline in the number of banks and credit unions actively banking marijuana-related businesses (MRBs) in the...more
First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more
Summary -
A bipartisan majority of the House of Representatives passed the Marijuana Opportunity Reinvestment and Expungement (MORE) Act, which would decriminalize cannabis at the federal level, impose certain federal...more
Regulators Provide Greater Transparency into BSA/AML Enforcement Process. On August 13, 2020, the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more
8/27/2020
/ Banking Sector ,
BSA/AML ,
Compliance ,
Enforcement Actions ,
Federal Bank Regulatory Agencies ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Internal Controls ,
Joint Statements ,
Transparency
Regulators Provide Greater Transparency into BSA/AML Enforcement Process -
On August 13, 2020 the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more
8/24/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Cease and Desist Orders ,
Compliance ,
Criminal Investigations ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Internal Controls ,
Joint Statements
Allocation of funds under the CARES Act Provider Relief Fund commenced on April 10, 2020, to address the economic impact of the pandemic on the U.S. healthcare system, including the heroic providers battling COVID-19....more
On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more
12/5/2019
/ Agribusiness ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Cannabis Products ,
Consumer Financial Products ,
Controlled Substances ,
Controlled Substances Act ,
Debit and Credit Card Transactions ,
Decriminalization of Marijuana ,
Deregulation ,
Farm Bill ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Hemp ,
Hemp Cultivation ,
Interstate Commerce ,
Marijuana ,
Marijuana Cultivation ,
Marijuana Related Businesses ,
New Guidance ,
OCC ,
Regulatory Oversight ,
Regulatory Requirements ,
Small Business Loans ,
Suspicious Activity Reports (SARs) ,
USDA
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
11/18/2019
/ Advisory Opinions ,
AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Bahamas ,
BSA/AML ,
Cambodia ,
Cooperative Compliance Regime ,
Corrective Actions ,
Corruption ,
Countermeasures ,
Cross-Border Transactions ,
Due Diligence ,
Economic Sanctions ,
Failure to Comply ,
FATF ,
Federal Agency Taskforce ,
Financial Institutions ,
FinCEN ,
Foreign Banks ,
Foreign Jurisdictions ,
Ghana ,
Iran ,
Money Laundering ,
Mongolia ,
North Korea ,
Pakistan ,
Panama ,
Prohibited Transactions ,
Public Statements ,
Risk Management ,
Risk-Based Approaches ,
Suspicious Activities ,
Syria ,
Terrorist Financing Regulations ,
White Collar Crimes ,
WMD ,
Yemen ,
Zimbabwe
Testimony Supports Bill Requiring States to Collect Beneficial Ownership Information at Entity Formation -
As we have blogged, the proposed Corporate Transparency Act of 2019 (the “Act”) seeks to ensure that persons who...more
5/24/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Structures ,
FATF ,
FBI ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Limited Liability Company (LLC) ,
Money Laundering ,
OCC ,
Regulatory Burden ,
Regulatory Standards ,
Senate Committees ,
Tax Evasion ,
Transparency
The state-legal marijuana industry in the United States continues to grow – as does support for it. Ten states and Washington, D.C. have legalized recreational adult use and 23 other states allow some form of medical...more
In early March, the House Financial Services Committee released three proposed bills to codify many of the suggested reforms discussed during ongoing conversation among financial agencies, law enforcement, financial...more
3/29/2019
/ AML/CFT ,
Beneficial Owner ,
BSA/AML ,
Financial Crimes ,
Financial Regulatory Reform ,
Financial Services Committee ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Reporting Requirements ,
Shell Corporations ,
Transparency ,
White Collar Crimes