Anti-Money Laundering

News & Analysis as of

AML and Sanctions Compliance Issues Facing Digital Currency and Blockchain Companies

The United States Department of Justice convened an unprecedented Summit on Digital Currency and the Blockchain on November 9, 2015. The reported goal of the Summit was to promote a dialogue between the government and...more

Corporate and Financial Weekly Digest - Volume X, Issue 45

SEC/CORPORATE SEC Commissioner Piwowar Speaks at Current Financial Reporting Issues Conference - On November 16, Securities and Exchange Commissioner Michael Piwowar addressed the 34th Annual Current Financial Reporting...more

Deputy Attorney General Yates Expands on DOJ’s White-Collar Prosecution Policy

On November 16, the DOJ’s Deputy AG Sally Yates delivered remarks at the American Bankers Association and American Bar Association Money Laundering Enforcement Conference. Yates focused her remarks on recent revisions –...more

The Attacks in Paris and AML Compliance

The attacks in Paris and subsequent events have horrified any right-minded person. The slaughter of innocent civilians sickened the world and the outpouring of support for the city of Paris; the country of France and the...more

Blog: European Council To Ask Commission To Strengthen Controls Over Electronic Payments & Virtual Currencies

It’s being widely reported in Europe this evening that, after tomorrow’s extraordinary meeting of the European Union’s Justice & Home Affairs Council meeting, the European Council will ask the Europe Commission to “present...more

Investment Management Legal + Regulatory Update - November 2015

Regulation - OCIE Cautions Advisers on Outsourcing Compliance Activities: In a Risk Alert dated November 9, 2015, the SEC’s Office of Compliance Inspections and Examinations (OCIE) said it found that outsourced...more

SEC Releases Risk Alert Related to Outsourcing of Chief Compliance Officer Duties by Investment Advisers and Investment Companies

On Nov. 9, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released a risk alert reporting observations from its examination of investment advisers and investment companies that outsource their Chief...more

FinCEN’s Expanding Application of the Bank Secrecy Act and Anti-Money Laundering Regulations

The Financial Crimes Enforcement Network (FinCEN) is again flexing its regulatory muscles by increasing the breadth and scope of the types of entities regulated by the Bank Secrecy Act (BSA). Among other things, the BSA...more

Caldwell Lays It Out – DOJ Metrics for a Compliance Program

Last week Assistant Attorney General Leslie R. Caldwell spoke at the SIFMA Compliance and Legal Society New York Regional Seminar. In this speech she discussed the new Department of Justice (DOJ) Compliance Counsel. While...more

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

Financial Regulatory Developments Focus - October 2015 #4

In this week's newsletter, we provide a snapshot of the principal US, European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

FATF updates guidance

FATF has published the outcomes of its plenary meeting in Paris. The main issues dealt with by this plenary were: - combating terrorist financing, which remains the top priority for FATF...more

Orrick's Financial Industry Week in Review

Barclays and Wachovia Settle with NCUA - On October 19, 2015, Barclays PLC and Wachovia Capital Markets LLC agreed to pay $325 million and $53 million, respectively, to settle claims brought by the National Credit Union...more

Joint Committee of ESAs Consults on Risk-Based Supervision and Risk Factors Guidelines

On October 21, 2015, the Joint Committee of the European Securities and Markets Authority, the European Banking Authority and the European Insurance and Occupational Pensions Authority (together, the European Supervisory...more

ESAs consult on AML/CTF

The European Supervisory Authorities (ESMA, EBA and EIOPA jointly) have launched a public consultation on two anti-money laundering and countering the financing of terrorism (AML/CFT) guidelines, to be made under the fourth...more

The Financial Report - Volume 4, No. 20 - October 2015 (Global)

Last Friday, the Securities and Exchange Commission published a 41-page report that provides private fund industry statistics and trends. The report aggregates data supplied by more than 2,600 private fund advisers on Form...more

Hastert Reaches Plea Deal in Anti-Money Laundering Case – Guilty Plea Expected

As I reported in a June 2, 2015 client alert, on May 28, 2015, Dennis Hastert, former Speaker of the U.S. House of Representatives, was indicted by a federal grand jury in the Northern District of Illinois. Mr. Hastert, a...more

ESAs publish 2016 work programme

The joint committee of the European Supervisory Authorities (ESAs) has published its work programme for 2016. The ESAs will carry on with their joint regulatory work in key areas such as packaged retail and insurance-based...more

Investment Management Update - October 2015

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Foreign Corrupt Practices Act 2015 Update

Despite a decline in enforcement actions by the Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the...more

AML Trends Signal Changing Times For Regional Banks

Recent activity involving state and federal bank regulators reflects an upswing in enforcement actions against regional and super-regional banks for Bank Secrecy Act/anti-money laundering compliance failures. Bank of Mingo,...more

Virtual Currencies: International Actions and Regulations

This chart is provided by Perkins Coie LLP’s Decentralized Virtual Currency industry practice group for informational purposes only and is not legal advice. This information is not intended to create, and receipt of it does...more

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

The CSBS Finalizes Model Framework for Virtual Currencies

On September 15, 2015, the Conference of State Bank Supervisors (“CSBS”) issued its final Model Regulatory Framework on virtual currency activities (“Final Framework”). The Final Framework follows the CSBS’s December 2014...more

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