Money Laundering

News & Analysis as of

FinCEN Issues Final Rule Imposing Special Measure Five Against FBME Bank Ltd.

On July 23, FinCEN issued a final rule pursuant to Section 311 of the USA PATRIOT Act to impose “special measure five” against FBME Bank Ltd. (“FBME”), formerly known as the Federal Bank of the Middle East. Special measure...more

Blog: CooleyAR’s summer holiday

However, before we pack our bags it is worth reflecting on David Cameron’s recent speech in Singapore where he addressed the threat posed by corruption worldwide. We were particularly interested in his comments on how the UK...more

Federal Reserve Orders Chinese Bank to Overhaul its BSA/AML Compliance Program

On July 21, a leading China-based bank agreed to address deficiencies in connection with the BSA/AML risk management and compliance program of its New York branch office. The Agreement, entered into with the Federal Reserve...more

The Fifth Letter and Expansion of the Brazilian Corruption Scandal into the Private Sector

I recently received a review copy of the book The Fifth Letter by fellow University of Michigan grad Vivian L. Carpenter. It is a rollicking good read which touches on areas of constitutional law, inalienable rights in the...more

DOJ Announces Charges Against Two Florida Men for Operating Underground Bitcoin Exchange

On July 21, U.S. Attorney for the Southern District of New York Preet Bharara, along with the Assistant Director-in-Charge of the New York Field Office of the FBI and the Special Agent-in-Charge of the New York Field Office...more

Bitcoin Week in Review 07.20.15 – 07.24.15

Domestic Developments - Florida. Anthony Murgio and Yuri Lebedev, operators of bitcoin exchange service Coin.mx were arrested on July 21, 2015 for operating the exchange without a money transmission license. The U.S....more

Data Privacy and Passenger Name Records - MEPs Approve EU Rules With Data Protection Safeguards

Draft EU rules on sharing and protecting Passenger Name Record (PNR) data of people flying to or from the EU, were approved by the Civil Liberties Committee on 15 July 2015. Once passed into law, this data will be collected...more

Blog: A Proposal To Extend Beneficial Ownership Rules To UK Land-Holding Foreign Companies

A report published yesterday by Global Witness, alleging that an individual with ties to a former Kazakh public official owns large swathes of London, follows much recent interest in the issue of public officials owning...more

BCBS Consults on Proposed Revised Version of General Guide to Account Opening

On July 16, 2015, the Basel Committee on Banking Supervision (BCBS) issued a consultation paper on a proposed revised version of its general guide to account opening. The guide was first published in February 2003. The...more

Big sweepstakes scam artists don’t cry

According to the Edmonton Sun newspaper, Nigerian-born Richard Mmah Chukwu, a resident of Edmonton, was recently convicted of implementing a multi-million dollar sweepstakes scam. Chukwu was found guilty in the Canadian...more

Governance & Securities Law Focus: Europe Edition - July 2015

In this issue: - Financial Reporting: Commission Delegated Regulations on Equivalence of Certain Third Country National GAAPs to IFRS - Proxy Advisers: ESMA Consultation on Best Practise Principles for Voting...more

Rolling the Dice: Casinos, FinCEN and AML Compliance

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML...more

Scrutinizing Third-Party Payments

It is often hard to convince people that receiving money can be a problem. Everyone likes to receive money, especially when they are being paid for something they did. In the area of compliance priorities, companies do not...more

Top Ten International Anti-Corruption Developments for June 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

June FCPA Compliance Digest | BONUS: Global Anti-Corruption and Anti-Money Laundering News

I love writing articles where I get to discuss companies making history. PetroTiger has been exonerated from criminal FCPA prosecution by the DOJ. That’s only happened once before, in the case of Morgan Stanley....more

Business Litigation Report - June 2015

In This Issue: ..From 20 Years to Zero in Six Trial Days - Noted With Interest: ..FedEx Drivers: Employees or Independent Contractors? The Ninth Circuit Weighs in on California’s Murky “Right-to-Control”...more

Lines Crossed: From Enforcing to Breaking the Law

Silk Road was a notorious black market for narcotics that used seemingly untraceable digital currencies (i.e., Bitcoins) to facilitate illegal activities on the “dark web.” Last week, former Drug Enforcement Agency (“DEA”)...more

Corporate Investigations & White Collar Defense - June 2015

The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card? - Why it matters: The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing...more

Former Qualcomm Executive Sentenced For Insider Trading

Jing Wang, a former Qualcomm Inc. Executive Vice President began by constructing a cover-up. Then he engaged in insider trading, using inside information taken from his employer. The scheme failed. Mr. Wang has been sentenced...more

[Webinar] How EU Companies Can Implement & Demonstrate Effective Anti Bribery Compliance in Emerging Markets - July 9, 9:00 am EST

European companies subject to FCPA jurisdiction or comparable European jurisdictions, and doing business in emerging markets such as the BRIC nations, face a rigorous compliance standard. Firms must have compliance processes...more

Letter from America: Non-Us Companies And Executives At Risk From Us RICO Law

More frequently than ever before, American plaintiffs and prosecutors are using U.S. laws to target conduct that has little, if any, connection to the United States. Potential exposure to criminal and civil liability under...more

Treasury Department Publishes National Money Laundering Risk Assessment and National Terrorist Financing Risk Assessment

On June 12, 2015, Treasury Department issued its National Money Laundering Risk Assessment (NMLRA) and National Terrorist Financing Risk Assessment (NTFRA). This is the Department’s first NMLRA release in a decade and its...more

Money Laundering Crackdown in Real Estate Sector?

The Director of the Financial Crimes Enforcement Network (also known as FinCEN) recently gave a speech in San Francisco regarding the agency’s investigative priorities. Director Jennifer Shasky Calvery’s comments drew media...more

Global Connection - June 2015

The latest edition of Global Connection offers insight into a potential money laundering crackdown in the real estate sector, information on the Federal Trade Commission’s approach to data breach investigations and a legal...more

The FIFA Scandal: The Long Foot of American Justice

Envelopes of cash. Vote rigging. Wiretapped recordings in 5-star hotel rooms. A dramatic early morning police raid coordinated between the FBI and Swiss law enforcement. An episode of the Sopranos? No, but it is a day in the...more

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