President Biden recently signed into law the Foreign Extortion Prevention Act (“FEPA”), enabling federal prosecution of non-U.S. government officials who solicit or receive bribes.
FEPA complements the Foreign Corrupt...more
1/23/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Bribery ,
Department of Justice (DOJ) ,
Economic Sanctions ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Foreign Official ,
Securities Exchange Act of 1934 ,
Wire Fraud
In a recent judgment, the English High Court for the first time ruled on a sanctions de-listing case under Section 38 of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”). Following the UK’s departure from the EU,...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule (Proposed Rule) on December 15, 2022, implementing the requirements of Section 6403 of the Corporate Transparency Act (Act)...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on September 29, 2022 issued a final rule (Final Rule) defining and implementing the beneficial ownership reporting requirements of Section 6403...more
12/1/2022
/ Anti-Money Laundering ,
Beneficial Owner ,
Commodity Exchange Act (CEA) ,
Corporate Transparency Act ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Investment Advisers Act of 1940 ,
Investment Company Act of 1940 ,
Limited Liability Company (LLC) ,
Ownership Interest ,
Pooled Investment Vehicles ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934
On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed new regulations (“Proposed Regulations”) defining and implementing the beneficial ownership reporting...more
12/23/2021
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Proposed Regulation ,
Regulatory Requirements
The Financial Action Task Force ("FATF"), the global money laundering and terrorist financing (“ML/TF”) watchdog, recently issued updated guidance related to compliance risks resulting from activities involving Virtual Assets...more
12/22/2021
/ Anti-Money Laundering ,
Decentralized Finance (DeFi) ,
Digital Assets ,
FATF ,
Financial Services Industry ,
Guidance Update ,
Money Laundering ,
Non-Fungible Tokens (NFTs) ,
Peer-to-Peer ,
Regulatory Oversight ,
Risk-Based Approaches ,
Stablecoins ,
Virtual Currency
The Anti-Money Laundering Act of 2020 (AML Act), enacted on January 1, 2021 as part of the National Defense Authorization Act for Fiscal Year of 2021 (NDAA), makes several significant changes to U.S. anti-money laundering...more
2/23/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Disgorgement ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
NDAA ,
New Legislation ,
Pooled Investment Vehicles ,
Regulatory Agenda ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Suspicious Activity Reports (SARs) ,
Whistleblowers
In 2017 there were a number of major sanctions developments in the EU and the US, with implications for businesses both in terms of keeping their compliance processes effective, and in terms of what to do if breaches are...more
2/6/2018
/ Anti-Money Laundering ,
CAATSA ,
Compliance ,
Economic Sanctions ,
EU ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
North Korea ,
Nuclear Power ,
Office of Financial Sanctions Implementation (OFSI) ,
Russia ,
Sovereign Debt ,
UK ,
UK Brexit ,
Venezuela
As required under the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), the Trump Administration on Monday released an unclassified version of a report (the “Report”) identifying senior political figures and...more
1/31/2018
/ Anti-Corruption ,
Anti-Money Laundering ,
Banks ,
Blocked Entities ,
Blocked Person ,
CAATSA ,
Economic Sanctions ,
Russia ,
SDN List ,
Trump Administration ,
US State Departments
The U.S. Department of the Treasury, together with other U.S. government agencies responsible for enforcing anti-money laundering (AML) and economic sanctions regulations, released guidance on August 30, 2016 in the form of a...more
9/1/2016
/ Anti-Money Laundering ,
Compliance ,
Depository Institutions ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Foreign Correspondent Banking ,
Foreign Financial Institutions (FFI) ,
Joint Policy Statements ,
New Guidance ,
U.S. Treasury
Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more
1/30/2014
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Compliance ,
FinCEN ,
Foreign Banks ,
Iran ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
U.S. Treasury