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Personal Liability Exposure for Bank Executives and Compliance Officers

On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its assessment of a civil monetary penalty totaling $450,000 against Michael LaFontaine, a former Chief Operational...more

Virtual Currency as a Threat to National Security?

In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more

Tying It All Together: FinCEN Consolidates Several Years of Cryptocurrency Guidance

For the past several years, advocates of crypto assets and other public uses of blockchain technology have sought guidance from U.S. regulators regarding the legal implications of new or novel uses of that technology....more

New York Department of Financial Services Intensifies AML Enforcement Under New Superintendent

Superintendent of New York State Department of Financial Services (“NYDFS”), Maria T. Vullo, has focused the Department’s efforts on enforcement of New York’s Anti-Money Laundering (“AML”) laws. Since her confirmation on June...more

FinCEN Issues Advisory on Cyber Crime

On October 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published an Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime and an accompanying Frequently Asked...more

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