On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more
5/14/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Services Business ,
Money Transmitter ,
Policy Statement ,
Virtual Currency
On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more
4/24/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Digital Wallets ,
Internal Revenue Code (IRC) ,
IRS ,
Know Your Customers ,
Reporting Requirements
Incorporating in the Seychelles but Allegedly Operating in the U.S. Spells Trouble for Company and its Founders -
The Bitcoin Mercantile Exchange, or BitMEX, is a large and well-known online trading platform dealing in...more
10/13/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bribery ,
BSA/AML ,
CFTC ,
Commodity Exchange Act (CEA) ,
Corporate Counsel ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Financial Institutions ,
Indictments ,
Know Your Customers ,
Registration Requirement ,
Suspicious Activity Reports (SARs) ,
Trading Platforms
For years, lawyers have been in the cross hairs of prosecutors and regulators, who sometimes regard lawyers as potential gatekeepers responsible for preventing wrongdoing by clients....more
Address Emphasizes Role of SARs in Fighting Illegal Activity, Including Drug Dealing Fueling the Opioid Crisis -
Kenneth Blanco, the Director of the Financial Crimes Enforcement Network (“FinCEN”), discussed last week...more
8/13/2018
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
Cryptocurrency ,
Digital Currency ,
Filing Requirements ,
Financial Crimes ,
FinCEN ,
Illegal Drugs ,
Information Sharing ,
Initial Coin Offering (ICOs) ,
Money Services Business ,
Opioid ,
Regulatory Oversight ,
Regulatory Standards ,
Suspicious Activity Reports (SARs) ,
Virtual Currency
On February 23, the Financial Action Task Force (“FATF”) signaled that the inter-governmental body “will step up its efforts in monitoring the use of cryptocurrencies in money laundering.” ...more
3/2/2018
/ Anti-Money Laundering ,
Banking Sector ,
Bitcoin ,
Cryptocurrency ,
Digital Currency ,
FATF ,
G20 ,
Initial Coin Offering (ICOs) ,
Money Laundering ,
Regulatory Oversight ,
Risk Management ,
Token Sales ,
Virtual Currency
As the value of bitcoin continues to soar (USD:BTC this past weekend exceeded $19,000.00:1), we thought that now would be a good time to emphasize the need to ensure regulatory compliance with the many federal and state AML...more
12/22/2017
/ Anti-Money Laundering ,
Bitcoin ,
BitLicense ,
BSA/AML ,
Cryptocurrency ,
Digital Currency ,
Financial Services Industry ,
FinCEN ,
Know Your Customers ,
Money Services Business ,
Virtual Currency
The Philippines has been identified by the U.S. as a “major money-laundering country” in the 2017 International Narcotics Control Strategy Report (“Report”), published this month. The country now joins 87 others as one “whose...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
For the second time in two years, Benjamin Lawsky, the Superintendent of the New York State Department of Financial Services (DFS), has settled another matter with Standard Chartered Bank for alleged “anti-money laundering...more
Benjamin M. Lawsky, who heads the New York State Department of Financial Services (DFS), indicated that his agency is seriously considering more aggressive investigation and pursuit of individuals whose malfeasance has led...more