Part III of the Analysis of the Combatting Money Laundering, Terrorist Financing, and Counterfeiting Act of 2017 -
As we recently blogged, Senators Chuck Grassley (R-Iowa) and Diane Feinstein (D-California) introduced on...more
Senators Chuck Grassley (R-Iowa) and Diane Feinstein (D-California) introduced on May 25, 2017 a bill, S. 1241, entitled the “Combatting Money Laundering, Terrorist Financing, and Counterfeiting Act of 2017.” Although it is...more
Today we are very pleased to welcome guest blogger Greg Baer, who will address a series of significant issues posed by a detailed paper published by The Clearing House, a banking association and payments company that is owned...more
5/9/2017
/ ACH Payments ,
AML/CFT ,
AUSA ,
Banking Sector ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Patriot Act ,
Regulatory Standards ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding
FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more
2/23/2017
/ Anti-Money Laundering ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Cash Transactions ,
FATF ,
Financial Institutions ,
FinCEN ,
Geographic Targeting Order ,
Insurance Industry ,
Money Laundering ,
Real Estate Investments ,
Real Estate Market ,
Reporting Requirements ,
Shell Corporations ,
Title Insurance
The Conference of State Bank Supervisors (CSBS) has continued its efforts to promote improvements in Bank Secrecy Act/Anti-Money Laundering compliance with the release in January 2017 of a new BSA/AML Self-Assessment Tool for...more
In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more
2/7/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
Bitcoin ,
BSA/AML ,
Civil Forfeiture ,
Currency Transaction Reports (CTR) ,
Digital Currency ,
Financial Institutions ,
Forfeiture ,
Money Laundering ,
Virtual Currency
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
2/3/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Casinos ,
Consumer Lenders ,
Customer Due Diligence (CDD) ,
FATF ,
Financial Institutions ,
FinCEN ,
Fines ,
Gambling ,
Gaming ,
Geographic Targeting Order ,
Money Laundering ,
Mortgage Lenders ,
Mortgages ,
NYDFS ,
Offshore Funds ,
Panama Papers ,
Popular ,
Real Estate Market ,
Suspicious Activity Reports (SARs) ,
Tax Evasion
The New York Department of Financial Services (NYDFS) announced today a revised regulation that will require all institutions subject to NYDFS supervision to establish and maintain a cybersecurity program meeting "certain...more
12/29/2016
/ Banking Sector ,
Banks ,
Chief Information Security Officer (CISO) ,
Comment Period ,
Cybersecurity ,
Cybersecurity Framework ,
Data Protection ,
Financial Institutions ,
Financial Services Industry ,
Insurance Industry ,
NYDFS ,
Risk Management ,
Third-Party Service Provider
The New York Department of Financial Services (NYDFS) will require all institutions subject to NYDFS supervision to establish and maintain a cybersecurity program meeting "certain regulatory minimum standards." All financial...more
9/20/2016
/ Banking Sector ,
Chief Information Security Officer (CISO) ,
Consumer Lenders ,
Cybersecurity ,
Financial Institutions ,
Financial Services Industry ,
Information Technology ,
Mortgages ,
NYDFS ,
Popular ,
Risk Management
The U.S. Department of the Treasury and four U.S. federal banking regulators have issued the "Joint Fact Sheet on Foreign Correspondent Banking" in an effort to clarify enforcement priorities regarding Anti-Money Laundering...more
9/2/2016
/ AML/CFT ,
Anti-Money Laundering ,
Banking Sector ,
Banks ,
BSA/AML ,
Depository Institutions ,
Due Diligence ,
Foreign Correspondent Banking ,
Foreign Financial Institutions (FFI) ,
International Monetary Fund ,
U.S. Treasury
FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more
8/5/2016
/ Banking Sector ,
Beneficial Owner ,
Cash Transactions ,
Covered Transactions ,
FinCEN ,
Geographic Targeting Order ,
Insurance Industry ,
Money Laundering ,
Real Estate Investments ,
Real Estate Market ,
Reporting Requirements ,
Title Insurance
The New York Department of Financial Services (DFS) has finalized a new regulation setting forth rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and...more
7/11/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Financial Institutions ,
Financial Regulatory Reform ,
Foreign Banks ,
Lenders ,
Money Laundering ,
Money Transmitter ,
Mortgages ,
New Regulations ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Transaction Monitoring
The New York Department of Financial Services (DFS) has finalized a new regulation setting rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and Bank...more
7/6/2016
/ Anti-Money Laundering ,
Banking Sector ,
BSA/AML ,
Certificates of Compliance ,
Disclosure Requirements ,
Financial Institutions ,
Foreign Banks ,
Money Transmitter ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Senior Managers ,
Transaction Monitoring
The federal body tasked with creating standards for the uniform regulation of financial institutions has released new information to assist examiners in evaluating mobile services offered by financial institutions and their...more
Following the trend of federal agency interest in fostering (and potentially regulating) innovation in the field of financial technology (FinTech), the Office of the Comptroller of the Currency (OCC) released the white paper...more
The New York Department of Financial Services (DFS) has proposed new regulations setting forth minimum standards for anti-money laundering (AML) transaction monitoring and filtering systems. The regulations, proposed December...more
The Federal Communications Commission (FCC) recently issued citations to two companies charged with violating the Telephone Consumer Protection Act (TCPA) consent requirements for autodialed or prerecorded calls to wireless...more
9/21/2015
/ Apple Pay ,
Banking Sector ,
Banks ,
Cell Phones ,
Class Action ,
Disclosure Requirements ,
FCC ,
Online Banking ,
Opt-Outs ,
Prior Express Consent ,
Right to Privacy ,
Robocalling ,
Smartphones ,
TCPA ,
Telecommunications ,
Telemarketing