Anti-Money Laundering

News & Analysis as of

BVI's National Risk Assessment scheduled

The British Virgin Islands (BVI) is scheduled to undergo its Fourth Round of Mutual Evaluation by the Caribbean Financial Action Task Force (CFATF) in 2017 based on the Financial Action Task Force’s (FATF) International...more

Digital Commerce & Payments Update

In this Issue: - Insights & Trends ..The Future of Regulation in the Digital Economy - Virtual Currency ..GAO Urges CFPB Participation In Virtual Currency Working Groups ..Trade Group White Paper...more

OCC Report Highlights Cybersecurity, BSA-AML, Indirect Auto Underwriting Concerns

On June 25, the OCC published its semiannual risk report, which provides an overview of the agency’s supervisory concerns for national banks and federal savings associations, including operational and compliance risks....more

Bitcoin and gaming – what legal issues?

Issues affecting Bitcoin and gaming are becoming a very frequent topic of discussion since a number of gaming websites decided to allow Bitcoin transactions and even relevant gambling regulators decided to take actions to...more

Council of EU Agrees on General Approach on the Fourth Money Laundering Directive and Revised Wire Transfer Regulation

On June 15, the Council of the EU published a note (dated June 13, 2014) outlining the general approach of the Presidency of the Council of the EU to the proposed Fourth Money Laundering Directive (MLD 4). On June 15,...more

FinCEN Doubles Down on Casinos with Heightened Regulatory Expectations - Casino Managers and Tribal Gaming Commissioners Need to...

For the second time in nine months, Financial Crimes Enforcement Network (FinCEN) Director Jennifer Shasky Calvery has publicly addressed FinCEN's increasing concerns regarding casino compliance with the Bank Secrecy Act...more

Court Orders Bank To Forfeit Funds Laundered With Assistance Of Branch Teller

On June 18, the U.S. Attorney for the District of Maryland announced that a federal judge ordered a bank to forfeit $560,000 in drug proceeds laundered through the bank on which the bank failed to file currency transaction...more

FTC Settlement with Payment Processor Highlights Importance of Anti-Money Laundering Programs for Non-Bank Financial Institutions

On June 11, 2014, the Federal Trade Commission (“FTC”) announced that it had entered into a stipulated permanent injunction with Independent Resources Network Corp., a payment processor, to settle charges that it knowingly...more

BNP Paribas and La Résistance: Why Compliance is not Capitulation and Cooperation Could Save an Economy

I will start by saying I am a proud Francophile. I love many things about French culture; from the just-right draw of their espresso (sorry, Italy, that ristretto is just too short and bitter) to the sacrosanct treatment of...more

Corporate Compliance Officers Face Threat of Civil Monetary Penalties and Criminal Prosecution for Institutional AML Deficiencies

While financial institutions have long faced the possibility of civil monetary penalties and criminal prosecution for violations of the Bank Secrecy Act (“BSA”) and its implementing regulations, found at 31 C.F.R. Chapter X,...more

Broker, Two Employees Alleged to Violate SEC Market Access Rule

The Commission’s inspection program, conducted by the Office of Compliance Inspections and Examinations or OCIE, has been the source of a number of enforcement actions. One example is the recently filed case against dark pool...more

The Financial Report - Volume 3, No. 11 • June 5, 2014 (Global)

Discussion and Analysis - FINRA recently simplified two rules that are critical in the public offering process. FINRA’s Corporate Financing Rule generally regulates underwriting compensation and prohibits unfair...more

Russian Legislation Update

In This Issue: - National Payment System - Anti-Money Laundering - Corporate: LLC Charter Capital, Personal Law of the Companies in the Crimea and Sevastopol, Accreditation - Corporate Governance Code -...more

Regulators Increasingly Pursue Individual Liability for Money-Laundering Violations

The Financial Crimes Enforcement Network (FinCEN), an arm of the U.S. Department of Treasury, recently fined a Miami-based money services business (MSB) and its owner $10,000 for failing to implement proper anti-money...more

AML/BSA Compliance Program Best Practices

I am always wary of definitive “best practices” lists. By definition, “best practices” vary depending on the size and nature of an organization in any compliance context....more

AML Compliance: The Four Pillars

With all the attention to Anti-Money Laundering and Bank Secrecy Act enforcement, I thought it would be a good time to review some basic AML ethics and compliance principles....more

BNA's Banking Report: Enforcement 2013: Enforcement Actions Continue Three-Year Decline; DOJ Emerges as Major Player

Overall Trends & Outlook - From an enforcement standpoint, 2013 was another historic year in a number of important ways beyond the sheer number of cases, which were again significant. Federal banking agencies1 issued...more

Common Sense In The Definition Of ‘Instrumentality’ Under The FCPA

In what can only be called a judicial decision based on common sense the 11th Circuit Court of Appeals, in an opinion released on May 16, upheld the convictions of Joel Esquenazi and Carlos Rodriguez for violations of the...more

Spain: New AML regulations have been approved

Yesterday the Spanish Official National Gazette published a new regulation developing the Spanish AML legislation (Royal Decree 304/2014, of 5 May 2014, approving the regulation developing Law 10/2010, of 28 April 2010, on...more

Anti Money Laundering Initiatives and Lawyers: What We Need to Know

Last Friday I was lucky enough to attend a Symposium at New York Law School entitled "Combating Threats to the International Financial System: The Financial Action Task Force." The Financial Action Task Force (FATF) is an...more

This Week In Securities Litigation (Week ending May 2, 2014)

Chair Mary Jo White testified before Congress this week. Her testimony focused on the budget, reviewing the recent work of the agency. The Commission brought a series of civil injunctive and administrative proceedings this...more

The Red Headed Stranger And The Arachnys Open Data Compass

Today we celebrate one of the great state of Texas’ greatest gifts to the musical world – the red headed stranger, Willie Nelson, who was born 29th April 1933. ...more

Revisiting The Corporate Top-10 FCPA Enforcement Actions

We all like organized lists. Short and sweet is easier to understand and ignore nuances. Even in our FCPA world, we track settlements by a top-10 lost. The concept of a top-10 predated David Letterman’s top-10 lists, and...more

International Financial Services Association Launches AML Working Group

On April 15, BAFT, an international financial services association for organizations engaged in international transaction banking, announced the creation of a new Anti-Money Laundering and Know Your Customer Trade Finance...more

Survey Finds Money Laundering Becoming a Top Priority for Management

Financial institutions are making significant adjustments in their approach to anti-money laundering (AML) compliance issues in the face of escalating global regulatory enforcement. According to KPMG’s 2014 AML Survey, 88% of...more

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