Anti-Money Laundering

News & Analysis as of

Luxembourg CSSF Circular 17/650 - Primary tax offences - In the fight against money laundering, what are your professional...

On 17 February 2017, Luxembourg’s financial regulator (Commission de Surveillance du Secteur Financier – CSSF) issued a circular drawn up with the Financial Intelligence Unit in order to provide...more

Hong Kong Proposes Enhanced AML Obligations for Professionals and Beneficial Owner Registries for Hong Kong Companies

The Hong Kong Government has recently proposed to expand its anti-money laundering (“AML”) laws. This is expected to assist Hong Kong in keeping pace with AML developments in other financial centers, and to prepare for its...more

OCIE and FINRA Announce 2017 Examination and Regulatory Priorities

On January 4 and January 12, 2017, respectively, the Financial Industry Regulatory Authority (“FINRA”) and the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”) each...more

AML Rules for Payment Industry Proposed by European Union Regulators

The Joint Committee of the European Supervisory Authorities (ESA) issued on February 10, 2017 draft rules regarding certain anti-money laundering (AML) and counter-terrorism steps for Member States of the European Union (EU)....more

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

UK Regulator Fines Deutsche Bank for AML Control Failings Related to Mirror Trading

The Financial Conduct Authority published a final notice issued to Deutsche Bank AG and fined the bank £163 million for failing to maintain an adequate anti-money laundering control framework between January 1, 2012 and...more

The Western Union DPA and the Need to Investigate One’s Own

The Western Union Company (“Western Union”) entered into a deferred prosecution agreement (“DPA”) on January 19th with the Department of Justice, based on alleged willful failures to maintain an effective AML program and the...more

SEC and FINRA Regulatory Priorities: Common Goals for 2017

Each year, both the United States Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) issue guidance concerning their regulatory priorities for the coming year. This year, FINRA...more

Bridging the Week - February 2017

Making Regulation Great Again: President Trump Requires Loss of Two Regulations for Every New One and Orders Review of All Financial Services Laws and Rules: Last week, through the issuance of two executive orders, President...more

2016 Year in Review: Money Laundering (Part Two)

In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more

2016 Year End Review: Banking Regulators Try to Ease Concerns Over Aggressive AML/BSA Enforcement

On August 30, 2016, the U.S. Department of the Treasury and four U.S. federal banking regulators sought to correct a problem—at least in part one of their own creation—by issuing a “Joint Fact Sheet on Foreign Correspondent...more

2016 Year End Review: Money Laundering Opinions of Note

The federal courts continued in 2016 to produce a stream of cases pertaining to money laundering. We focus on three below because they involve analysis of basic issues that frequently arise in money laundering litigation....more

The Sanctions Committees of the French Financial Regulators: Overview of the Activity in 2016

In 2016, the French financial regulators, the ACPR and the AMF, continued to pay particular attention to infringements in matters of anti-money laundering and anti-terrorism, internal control procedures, conflicts of interest...more

2016 Year in Review: Money Laundering (Part One)

2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

SEC Brings AML Charges Against New York Brokerage Firm and its Chief Compliance Officer

The SEC recently charged a New York-based broker-dealer, Windsor Street Capital, L.P. (f/k/a Meyers Associates, L.P.) and John David Telfer, who acted as Windsor’s Chief Compliance and Anti-Money Laundering Officer for...more

Recap and Analysis: Responsible Art Market Initiative Launched in Geneva

I was pleased to attend last week in Geneva “Building an Art Market for the Future—Guidelines for Countering Money Laundering and Terrorist Financing Threats” hosted by the Fondation pour le Droit d’Art (Art Law Foundation)...more

Anti-Money Laundering and Cybersecurity Among the 2017 SEC Examination Priorities

Earlier this month, the Securities and Exchange Commission (SEC) announced its Office of Compliance Inspections and Examinations’ (OCIE) 2017 Examination Priorities regarding certain practices, products, and services that...more

NYDFS, American Bankers Association Weigh In On OCC Fintech Charter Proposal

The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more

French Legal and Regulatory Update – December 2016

The Paris office of Hogan Lovells is pleased to provide this English language edition of our monthly e-newsletter, which offers a legal and regulatory update covering France and Europe for December 2016. Please see full...more

Western Union to Pay $586 Million in Restitution and Civil Penalties for AML Compliance Failure

On January 19, 2017, Western Union Financial Services, Inc. agreed to pay civil penalties and restitution to victims of fraud totaling $586 million to resolve actions brought by the U.S. Treasury Department’s Financial Crimes...more

Financial Regulatory Developments Focus - January 2017

In this 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 managers and...more

Year in Review: Legislation and Guidance for Financial Institutions in 2016

The regulation of federally regulated financial institutions (FRFIs) continued intensifying in 2016 with a new wave of legislative and regulatory initiatives impacting mortgage lending, the bank resolution regime, the life...more

European Commission Publishes Proposed Directive on Countering Money Laundering by Criminal Law 

The European Commission published a legislative proposal for a Directive on countering money laundering by criminal law. The proposed Directive is intended to harmonize and establish minimum rules concerning the definition of...more

OCIE 2017 Exam Priorities: Focus on Retail, Elderly and Retirement Investors; Market Risks

The SEC’s National Examination Program (NEA) of the Office of Compliance Inspections and Examinations (OCIE) announced that its examination priorities in 2017 will focus on three general areas: retail investors, risks...more

SEC Examination Priorities for 2017 – What do Robots, Senior Investors, and Payment for Order Flow Have in Common?

This week, the SEC’s Office of Compliance Inspections and Examinations (OCIE) released its Examination Priorities for 2017 that reflects certain practices, products, and services that OCIE perceives to present potentially...more

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