Anti-Money Laundering

News & Analysis as of

FinCEN Issues Advisory on FATF’s List of Jurisdictions with AML/CFT Deficiencies

On July 20, FinCEN issued an advisory to financial institutions with updates to the Financial Action Task Force’s (FATF) list of jurisdictions containing strategic anti-money laundering/counter-terrorist financing (AML/CFT)...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

Guide To Doing Business In New Zealand: Exchange Control (Updated)

EXCHANGE CONTROL - Currency movements in and out of New Zealand are subject to certain controls. The Anti-Money Laundering and Countering Financing of Terrorism Act 2009 imposes restrictions on transfer of money to...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

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

OCC Identifies Safety and Soundness Risks to National Banks and Federal Savings Associations and Supervisory Priorities

A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...more

The New Canadian Integrity Regime: Compliance Carrots to Join the Debarment Sticks

Today we welcome Kristine Robidoux, Partner, Gowling Lafleur Henderson LLP, for an analysis of the new Canadian Integrity Regime. As Canada has one of the most robust Debarment regimes which includes anti-bribery enforcement,...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

Know Your Customer (“KYC”) Due Diligence Best Practices

Financial institutions have a lengthy list of Anti-Money Laundering compliance requirements. They face a mountain of risks from a large number of financial transactions, each of which can carry significant risks. AML...more

BSA, AML Failures by West Virginia Bank Yield FDIC, FinCEN, DOJ Actions

Why it matters - In a coordinated effort, the U.S. government identified another “poster child” to demonstrate its continued vigilance and earnestness in pursuing lax BSA/AML procedures and oversight and violations of...more

Amendments to Canada’s Anti-Money Laundering Legislation: What’s New and What’s Next

On July 4, 2015, the federal government released amended regulations (Regulations) under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA). While there are some additional regulatory burdens...more

AML Risks and Compliance for Non-Financial Institutions

Consider yourself lucky if you work at a company that does not fall within the Title 31 of the US Code definition of a “financial institution.” I am being somewhat dramatic but it is important for every company to have an...more

FinCEN Fines MSB and Its Owner for Alleged BSA Violations

Today, FinCEN announced the assessment of a civil money penalty against a Los Angeles-based Money Services Business (MSB) and its owner for alleged violations of the Bank Secrecy Act (BSA). During a 2011 examination of the...more

West Virginia’s Bank of Mingo Pays $4.5 Million for BSA/AML Compliance Program Deficiencies, Showing that Small and Midsize...

A series of recent federal enforcement actions targeting weaknesses in financial institutions’ Bank Secrecy Act/anti–money laundering (BSA/AML) compliance programs continued on June 15, when the Department of Justice (DOJ),...more

State Regulation of Virtual Currency: A Recap

This may be the year of the virtual currency. Virtual currencies have garnered much media, investor, and government attention. But, as venture capital funding continues to pour into the industry—more than $1 billion is...more

Will Anti-Money Laundering Regulations be Extended to Investment Advisers?

It has been more than a decade since the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) first proposed imposing anti-money laundering (“AML”) requirements on investment advisers. While FinCEN has yet to...more

FinCEN Enforcement Stacks the Deck in AML Compliance for Casinos and Card Clubs

Stephanie Booker, Associate Director for Enforcement, Financial Crimes Enforcement Network (“FinCEN”), recently gave a speech at the Nevada Bar Association’s Bank Secrecy Act Conference in Las Vegas. Involved in the...more

AML Compliance Expectations Unabated—Fines, Enforcement Actions and a Deferred Prosecution Agreement Against Banks, Money...

Why it matters - Three Financial Crimes Enforcement Network (FinCEN) orders, three sets of fines and asset forfeitures, a deferred prosecution agreement and one bank enforcement action demonstrate the resolve of the...more

The Next Examination Enforcement Wave— Cybersecurity Assessments?

Why it matters - The member banking agencies of the Office of the Federal Financial Institutions Examination Council (FFIEC) will soon promulgate a “Cybersecurity Assessment Tool” for use by community banks after a pilot...more

Broker-Dealers File Suspiciously Few Suspicious Activity Reports

Speaking at an anti-money laundering (AML) conference in February, SEC Director of Enforcement John Ceresney warned attendees that broker-dealers were under-filing suspicious activity reports (SARs). He said that...more

Small Local Bank Agrees to $4.5 Million Penalty for Ineffective Anti-Money Laundering Program and Structured Transactions

On June 15, multiple federal agencies issued a $4.5 million penalty against a local bank that admitted to failing to maintain an effective anti-money laundering program. The coordinated enforcement action by multiple agencies...more

Treasury Department Issues Comprehensive Assessment of US Money Laundering and Terrorist Financing Risk

For the first time in a decade, the Treasury Department has released its own anti–money laundering (AML) and terrorist financing Risk Assessments, which may both set a strategic framework for future AML regulatory...more

Financial Services Weekly News Roundup - June 2015 #3

Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more

New EU Rules on Disclosure of Ultimate Beneficial Owners

On June 5, new EU’s anti-money laundering (AML) rules, namely the Fourth EU Anti-Money Laundering Directive (“4AMLD”) and a new Regulation on the information accompanying transfer of funds were published in the Official...more

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