FinCEN has announced the expansion of its Geographical Targeting Orders (GTOs) for high-end cash buyers of real estate. The expansion is two-fold. First, FinCEN has expanded the scope of Form 8300 reportable transactions to...more
8/24/2017
/ Beneficial Owner ,
BSA/AML ,
FATF ,
Financial Institutions ,
FinCEN ,
GTO ,
Money Laundering ,
Real Estate Investments ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Title Insurance
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
The Joint Committee of the European Supervisory Authorities (ESA) issued on February 10, 2017 draft rules regarding certain anti-money laundering (AML) and counter-terrorism steps for Member States of the European Union (EU)....more
2/13/2017
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Cross-Border Transactions ,
EU ,
European Supervisory Authorities (ESAs) ,
Financial Institutions ,
Member State ,
Money Laundering ,
Money Transmitter ,
Payment Systems ,
Proposed Rules ,
Regulatory Oversight ,
Terrorism Funding ,
Terrorist Financing Regulations
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 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
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 Financial Crimes Enforcement Network's (FinCEN) continuing efforts to address the "real estate industry's vulnerability to money laundering” were outlined by FinCEN Director Jennifer Shasky Calvery in an April 12, 2016,...more
The Financial Crimes Enforcement Network (FinCEN) announced its first enforcement action against a small “card club” gaming establishment imposing a civil penalty of $650,000. The enforcement action, announced December 17,...more