Fourth Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”), contains major changes to the Bank Secrecy Act (“BSA”), coupled...more
Testimony Supports Bill Requiring States to Collect Beneficial Ownership Information at Entity Formation -
As we have blogged, the proposed Corporate Transparency Act of 2019 (the “Act”) seeks to ensure that persons who...more
5/24/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Structures ,
FATF ,
FBI ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Limited Liability Company (LLC) ,
Money Laundering ,
OCC ,
Regulatory Burden ,
Regulatory Standards ,
Senate Committees ,
Tax Evasion ,
Transparency
For the first time, a broker-dealer, Central States Capital Markets, LLC (Central States), has been prosecuted for violating the Bank Secrecy Act (BSA). ...more
1/4/2019
/ Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Cease and Desist Orders ,
Customer Identification Program (CIP) ,
Deferred Prosecution Agreements ,
Money Laundering ,
Native American Issues ,
Payday Loans ,
Regulatory Violations ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Usury
Part One of a Three-Part Series -
We begin this week with a three-part series on banking and the marijuana industry. States continue to pass medical and recreational use marijuana legislation despite that the fact that the...more
7/11/2017
/ Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Cole Memorandum ,
Decriminalization of Marijuana ,
Department of Justice (DOJ) ,
Dispensaries ,
FinCEN ,
Marijuana ,
Marijuana Related Businesses ,
SAR
Employers increasingly face the difficult scenario of employees who misappropriate company data in the pursuit of whistleblower claims alleging misconduct by the employer. Such cases can present a complex mix of regulatory,...more
2/24/2017
/ Bank Secrecy Act ,
Banking Sector ,
Banks ,
Confidentiality Agreements ,
Dodd-Frank ,
Labor Code ,
OCC ,
Retaliation ,
Sarbanes-Oxley ,
Securities and Exchange Commission (SEC) ,
Whistleblower Protection Policies ,
Whistleblowers
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
On August 30, 2016, the U.S. Department of the Treasury and four U.S. federal banking regulators sought to correct a problem—at least in part one of their own creation—by issuing a “Joint Fact Sheet on Foreign Correspondent...more
2/7/2017
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Due Diligence ,
Financial Institutions ,
Foreign Financial Institutions (FFI) ,
IMF ,
Money Laundering ,
Regulatory Oversight ,
Risk Management
The field of forfeiture saw significant action in 2016. The IRS offered to return forfeited funds used in structuring, but Congress still may clip its ability to forfeit such funds. Meanwhile, DOJ renewed a controversial...more
2/7/2017
/ Asset Seizure ,
Bank Secrecy Act ,
BSA/AML ,
Criminal Investigations ,
Currency Transaction Reports (CTR) ,
Department of Justice (DOJ) ,
Financial Institutions ,
Forfeiture ,
IRS ,
Luis v United States ,
Money Laundering ,
SCOTUS ,
Sixth Amendment
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