Ross Delston – Law Office of Ross Delston

FinCEN Proposal for Investment Advisers Clears OMB Hurdle

Proposed FinCEN regulation that would require AML programs and SAR filing…more
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FATF Pushes Risk-Based Approach Toward Virtual Currencies, Services, WSJ Risk & Compliance Journal, 7/2/15

Virtual currency payment products and services expose the global financial system to money laundering and terrorism financing risk, and their growing presence requires a risk-based approach to mitigate the potential ill effects,…more
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FATF’s Latest Round of Evaluations Proving Challenging for Some Nations

The Financial Action Task Force will work in the coming year to help nations struggling to adjust to its revised evaluation methodology, the intergovernmental group’s new president said Wednesday. In an outline of his…more
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Strengthening Our Security: A New International Standard on Trade-Based Money Laundering is Needed Now (co-authored with Stephen Walls), 44 Case Western Reserve Journal of International Law 737 (2012)

In 2012, the Financial Action Task Force (FATF) missed an opportunity to address trade-based money laundering (TBML) in its International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation,…more
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U.S. Publishes FATF-Mandated Risk Assessments Ahead of Mutual Evaluation

News article covering release by U.S. Treasury Department of national risk assessments on money laundering and terrorist financing. BSA/AML, AML/CFT, vulnerabilities, banks, depository institutions, financial institutions…more
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Insights: Did FinCEN Just Burst Bitcoin's Bubble?

When FinCEN issued its innocuously entitled guidance, “Application of FinCEN’s Regulations to Persons Administering, Exchanging, or Using Virtual Currencies” on March 18, an already speculative currency may have received its…more
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Reaching Beyond Banks: How to Target Trade-based Money Laundering and Terrorist Financing Through Preventive Measures Outside the Financial Sector

Our thesis is that all those in the supply chain - exporters, importers, freight forwarders, carriers - should be subject to anti-money laundering/counter-terrorist financing (AML/CFT) preventive measures such as customer due…more
| Administrative Law, Criminal Law, Finance & Banking, International Law & Trade

"To Protect or Not to Protect, That Is the Question:" Statutory Protections for Financial Supervisors-How to Promote Financial Stability by Enacting the Right Laws

This article, published in Current Developments in Monetary and Financial Law, Vol. 5 (IMF 2008), considers the possible legal protections that should be extended to financial supervisors. It begins with a discussion of why such…more
| Administrative Law, Business Torts, Finance & Banking, International Law & Trade

Independent AML Audit - Essential Element or Nice to Have?

A comparison of US and EU/UK requirements, processes and procedures regarding anti-money laundering (AML) audits. Also discusses international standards - the Financial Action Task Force (FATF) Recommendations - on AML audits…more
| Administrative Law, Criminal Law, Finance & Banking, International Law & Trade

Lawyers as the New Guardians of Governance, op-ed piece, July/Aug. 2004, Amicus Curiae, Journal of the Society for Advanced Legal Studies (London).

A curious thing has happened of late: lawyers have been appointed by the international community as the new guardians of governance for their clients. More specifically, lawyers are increasingly regarded as part of the…more
| Administrative Law, Criminal Law, Finance & Banking, International Law & Trade, Law Practice Products & Services

Five Observations About Banking Failures, Current Developments in Monetary and Financial Law, Vol. 2 (IMF 2003).

Every Bank Failure Is a Regulatory Failure Certainly banks do not fail only because regulators fail in their oversight responsibilities. Many other failures are typically involved in any bank failure, including failures of…more
| Administrative Law, Bankruptcy, Finance & Banking, International Law & Trade

The 41st FATF Recommendation: Why Preventive Measures Targeting Trade-Based Money Laundering Should Reach Beyond Banks

It is an open secret that the Financial Action Task Force (FATF), is considering a new recommendation on trade-based money laundering. Its intentions were telegraphed by the publication in June 2006 of its monograph entitled…more
| Administrative Law, Criminal Law, Finance & Banking, International Law & Trade
Contact


Washington, DC, United States

  • 202-494-5835
  • 202-280-1465

Areas of Practice
  • Administrative Law
  • Class Action
  • Finance & Banking
  • International Law & Trade
  • Litigation
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