Anti-Money Laundering

News & Analysis as of

Is It Possible to Dodge Liability for Anti-Money Laundering?

Dodge, duck, dip, dive, and… dodge. Unfortunately, these five rules apply not only to dodgeball players but also to employees attempting to evade detection as they engage in money laundering and other financial crimes. As...more

New AML Licence Conditions and Guidance from the Gambling Commission

Following an extensive consultation in 2015 on changes to the LCCP in relation to the prevention of crimes associated with gambling, and two short consultations in June 2016 on digital adverts and money laundering risks, the...more

Singapore Legal Update - August 2016

MAS Proposes Enhancements to the Regulatory Requirements on Protection of Customer’s Moneys and Assets - The MAS Consultation Paper on Enhancements to the Regulatory Requirements on Protection of Customer’s Moneys and...more

FinCEN Expands Crackdown on Real Estate Buyers

Building on early successes, the Financial Crimes Enforcement Network (“FinCEN”) announced new rules targeting buyers of high-end real estate properties. Earlier this year, FinCEN adopted rules focusing on high-end...more

European Banking Authority Opines on Virtual Currencies and the Fourth Anti-Money Laundering Directive

The European Banking Authority published an Opinion on the Commission’s proposed amendments to the Fourth Anti-Money Laundering Directive and its application to virtual currencies. The Commission is proposing to bring...more

FinCEN Expands Scope of “All Cash” GTOs

Continuing its efforts to deter the use of real estate as a vehicle to launder proceeds of criminal activity, the Financial Crimes Enforcement Network (FinCEN) recently announced its plan to extend the reach and time frame of...more

Offshore Enforcement Remains Top Priority of DOJ

Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivers remarks regarding the tax division's offshore tax enforcement efforts at the Panama Bankers Association Anti-Money-Laundering Conference...more

AML Update: The NYDFS’s New Anti-Money Laundering Regulation and its Annual Compliance Certification Requirement

This summer, one of the nation’s top state regulators for finance announced a major new AML regulation, providing a critical hook for regulatory liability for companies that lack effective anti-money laundering controls. An...more

Blog: Virtual currencies & the 4th Anti-money Laundering Directive: EBA criticizes Commission’s proposals

The European Banking Authority has published an Opinion, which criticizes the Commission’s approach to virtual currencies (VCs) and its proposed amendments to the 4th Anti-money Laundering Directive (4AMLD). In its 2014...more

Anti-Corruption Laws and Other International Risks – What it Means for the Real Estate Industry and How to Protect against Risks

Bribery, money laundering, and sanctions are key international risk areas for any global business, particularly those investing or operating in high-risk jurisdictions and industries. In addition to meaningful enforcement...more

The SBEEA: Register of Significant Beneficial Ownership

The SBEEA (Part I: People with Significant Control) - Against the backdrop of an increasing push for greater transparency of company ownership, the Small Business Enterprise and Employment Act 2015 (“SBEEA“) took effect on 6...more

Should Professional Service Providers Assume Greater AML Vigilance Responsibilities?

Because they are known as “gatekeepers” in the financial industry, Professional Service Providers (PSPs), Bankers, Brokers, Realtors, Casino Managers, Trust Fund Managers, Money Managers, etc., carry a level of responsibility...more

Russian Legislation Update: 9 May - 17 July 2016

Welcome to the most recent issue of our Russian Legislation Update, covering the period of 9 May - 17 July 2016. In this issue: - Civil relations - Currency Control - Anti-Money Laundering - Banking -...more

Russian Companies: Know Your UBOs

All Russian legal entities must obtain information on their ultimate beneficial owners. Russia has recently amended its anti-money laundering law to require that any legal entity, whether private or public (with limited...more

Anti-money laundering bulletin - Summer 2016

In this issue, we provide updates on anti-money laundering news and enforcement action, both in the UK and internationally, including - - FCA publishes consultant’s findings from research into bank de-risking -...more

Use of Shell Companies To Shield Identity Further Limited

On July 27, 2016 the Financial Crimes Enforcement Network, (FinCEN) of the Department of the Treasury issued expanded Geographic Targeting Orders (GTO) that will...more

Legal Alert: New York’s New BSA/AML Rule Imposes Monitoring, Filtering and Certification Requirements

On June 30, 2016, the New York Department of Financial Services (DFS) adopted a new anti-terrorism and anti-money laundering (AML) regulation (Final Rule) that builds on federal anti-money laundering requirements to address...more

Are Compliance Officers at Financial Institutions Now in the Hot Seat for Fines?

Otherwise reputable Financial Institutions continue being sanctioned for regulatory non-compliance. Well known “household” names continue receiving fines for failing to establish and implement adequate Anti-Money Laundering...more

Why is On-boarding and Off-boarding Bank Clients Important?

After the Panama Papers, and with the recent FinCEN final Customer Due Diligence (CDD) rule, U.S. financial institutions are further focused on tightening internal controls against money laundering, terrorist financing,...more

FinCEN Targets More Real Estate Deals for AML

Today, the Financial Crimes Enforcement Network (FinCEN) announced, effective August 28, 2016golden and continuing for 180 days, it is expanding its earlier Geographic Targeting Orders (GTO) requiring information about the...more

Blog: European Commission considers database to end crypto-currency anonymity

The European Commission has published a proposal that, if made and brought into force, will amend the 4th Anti-money Laundering Directive (4AMLD) before the Member States are required to transpose it into their national...more

FinCEN Adopts New Customer Due Diligence Requirements for Financial Institutions

The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has adopted new anti-money laundering (“AML”) regulations that impose additional customer due diligence requirements on certain financial institutions...more

Applying for a German Banking or Financial Services Licence

Due to Brexit developments, for many non-European investors the option to acquire a German banking or financial licence, including the attached benefit of being able to use the European passport regime, is a part of their...more

Blog: FCA castigates the principals of appointed representatives in the general insurance sector

The FCA has just published a damning Thematic Review: “Principals and their appointed representatives in the general insurance sector“. The FCA asked 190 network principals to complete an online survey; asked 15 of these...more

New York State Department of Financial Services Releases Final Regulations to Enhance Anti-Money Laundering and Sanctions...

Final regulations impose certification requirements on a financial institution’s Board of Directors or Senior Officer(s) relating to BSA/AML and OFAC compliance. The New York State Register today published the final...more

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