Law Enforcement Has Been Using GTO Data -
First of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering -
The U.S. Government Accountability Office (“GAO”) has issued a report on the status and...more
8/26/2020
/ Anti-Corruption ,
Attorney-Client Privilege ,
Beneficial Owner ,
BSA/AML ,
Civil Forfeiture ,
Department of Justice (DOJ) ,
FATF ,
Financial Institutions ,
FinCEN ,
GAO ,
GTO ,
Law Enforcement ,
Mortgage Lenders ,
Real Estate Transactions ,
Suspicious Activity Reports (SARs)
This fall, the U.S. Supreme Court will hear argument in Timbs v. State of Indiana, one of the most anticipated cases this term. At issue is whether the Eighth Amendment’s prohibition against excessive fines applies to state...more
On Friday, the Department of Justice (“DOJ”) filed a civil forfeiture complaint in the Southern District of Texas seeking recovery of approximately $144 million in assets that allegedly represent the proceeds of foreign...more
7/19/2017
/ Bribery ,
Civil Forfeiture ,
Corruption ,
Department of Justice (DOJ) ,
Energy Sector ,
Extraterritoriality Rules ,
Government Officials ,
Money Laundering ,
Nigeria ,
Oil & Gas ,
Real Estate Market ,
White Collar Crimes
On the eve of trial this past Friday, the government announced an agreement to settle, subject to court approval, a major civil forfeiture action in the Southern District of New York. In the case, United States v. Prevezon...more
5/16/2017
/ Banking Sector ,
Civil Forfeiture ,
Extraterritoriality Rules ,
Foreign Investment Fund ,
Money Laundering ,
Real Estate Investments ,
Russia ,
Shell Corporations ,
Tax Fraud ,
Tax Refunds ,
Transfer of Assets
In this post, we consider the Department of Justice’s (DOJ) Office of the Inspector General report (OIG Report), released on March 29, 2017, evaluating the DOJ’s oversight of its cash seizure and forfeiture operations. This...more
4/12/2017
/ Asset Seizure ,
Civil Forfeiture ,
Criminal Investigations ,
Data Collection ,
DEA ,
Department of Justice (DOJ) ,
Forfeiture ,
IRS ,
Money Laundering ,
OIG ,
Tax Structuring
Forfeiture actions by Internal Revenue Service Criminal Investigation (IRS CI) based on alleged structuring activity have come under fire, yet again. Specifically, the Treasury Inspector General for Tax Administration (TIGTA)...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
The federal courts continued in 2016 to produce a stream of cases pertaining to money laundering. We focus on three below because they involve analysis of basic issues that frequently arise in money laundering litigation....more
2/7/2017
/ Anti-Money Laundering ,
Banking Sector ,
Banks ,
BSA/AML ,
Civil Forfeiture ,
Cross-Border Transactions ,
Currency Transaction Reports (CTR) ,
Department of Justice (DOJ) ,
Energy Sector ,
Financial Institutions ,
Fraud ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Iran Sanctions ,
Money Laundering ,
Private Equity ,
Summary Judgment ,
Taylor v US ,
Wire Fraud