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Bank Secrecy Act Regulatory Oversight

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
Guidepost Solutions LLC

Can a Failed Privacy Program Lead to Fentanyl Trafficking or OFAC Violations?

In July 2024, the Federal Bureau of Investigation and Department of Treasury’s Financial Crime Enforcement Network and Office of Foreign Assets Control (OFAC) released a joint notice discussing how Mexican-based Transnational...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Kohn, Kohn & Colapinto LLP

Cryptocurrencies Mirrored a New Gold Rush, Then Ended Up Similarly: With Scammers Going to Jail

Despite the excitement that surrounded original cryptocurrencies like Bitcoin, the dust eventually settled, revealing that only a few early investors got rich and many others lost their life savings. But it was not long...more

Eversheds Sutherland (US) LLP

Stablecoins: some key regulatory and enforcement initiatives of US regulators

During the past few months, the US Treasury, the US banking agencies, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have pursued several regulatory or enforcement initiatives...more

Holland & Knight LLP

FINRA Issues Guidance on FinCEN AML/CFT Priorities

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The Financial Industry Regulatory Authority (FINRA) issued a regulatory notice on Oct. 8, 2021, encouraging its broker-dealer members to review and prepare to incorporate into their own compliance programs the national...more

Latham & Watkins LLP

New US Digital Assets Bill Casts Wide Net

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An ambitious proposal could bring digital assets into the mainstream regulatory fold. During an eventful summer for the digital assets industry, it may have been easy to miss US Representative Don Beyer’s introduction of the...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

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Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Ballard Spahr LLP

Guilty Pleas Highlight Illicit Funneling of Chinese Cash to Casinos

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Government Suggests that Unusual Pleas are Just the Tip of an Iceberg - Chinese law generally prohibits its citizens from converting more than $50,000 in Chinese yuan into foreign currency in a year.  On Monday, two men...more

Stinson LLP

Missouri Financial Institutions Must Prepare for Impending Marijuana Banking Challenges

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In November 2018, Missouri voters passed Amendment 2, setting in motion state regulated medical marijuana. Over the last month, the Missouri Department of Health & Senior Services (DHSS) began approving license applications...more

Ballard Spahr LLP

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

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On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

Orrick - On the Chain

In Case You Needed A Reminder – AML/CFT Regulations Apply to Transactions in Cryptocurrencies

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Earlier this month, the leaders of the U.S. Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, and the U.S. Securities and Exchange Commission released a joint statement reminding individuals...more

Burns & Levinson LLP

When Privacy Does Not Apply, But Tax Does: Cryptocurrency Transactions

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Overview of Federal Regulation - As transactions involving cryptocurrencies, such as Bitcoin, become more prevalent, regulatory oversight has been evolving....more

Orrick - On the Chain

FinCEN’s New Guidance for Cryptocurrency Businesses – Some Questions Answered, Some New Questions Raised, Careful Consideration a...

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Last month, the Financial Crimes Enforcement Network (FinCEN) released new guidance to clarify when the Bank Secrecy Act (BSA) will apply to businesses that involve cryptocurrencies (what FinCEN refers to as convertible...more

Wilson Sonsini Goodrich & Rosati

Regulatory Landscape for Fintech, Electronic Commerce, and Electronic Banking: Part One

Part 1: Electronic Commerce - This is the first part of a two-part article discussing the regulatory landscape for financial technology as applied to electronic commerce and electronic banking. This article focuses on...more

Ballard Spahr LLP

Federal Banking Agencies Encourage BSA Resource Sharing

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Five U.S. regulatory agencies—the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), the Office of the Comptroller...more

Ballard Spahr LLP

FinCEN Issues Exceptive Relief from Beneficial Ownership Rule to Certain Account Renewals

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FinCEN Cites Low Risk of Money Laundering and High Regulatory Burden of Rule - On September 7, 2018, the Financial Crimes Enforcement Network (“FinCEN”) issued permanent exceptive relief (“Relief”) to the Beneficial...more

Ballard Spahr LLP

FinCEN Director Addresses Virtual Currency and Touts Regulatory Leadership and Value of SAR Filings

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Address Emphasizes Role of SARs in Fighting Illegal Activity, Including Drug Dealing Fueling the Opioid Crisis - Kenneth Blanco, the Director of the Financial Crimes Enforcement Network (“FinCEN”), discussed last week...more

Perkins Coie

Virtual Currency: Anti-Money Laundering and Terrorist Financing Update

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On July 18, 2018, the Financial Action Task Force (“FATF”), published its report to the July 2018 G20 Finance Ministers and Central Bank Governors’ meeting. The report sets out FATF’s ongoing work to fight money laundering...more

Foodman CPAs & Advisors

Did you know that Casinos are Financial Institutions?

Since 1985, Casinos that have Gross Annual Gaming Revenues in excess of $1,000,000 are considered to be Financial Institutions and are subject to the requirements of the Bank Secrecy Act (BSA). ...more

Ballard Spahr LLP

FinCEN Fines Texas Bank $2M for Alleged Failure to Vet and Monitor Mexican Correspondent Banking Relationship – But Touts Bank’s...

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FinCEN recentlty announced entry of a $2 million assessment against Lone Star National Bank, a private bank operating out of Texas, for the bank’s allegedly willful violations of the Bank Secrecy Act (“BSA”) and inadequate...more

Ballard Spahr LLP

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

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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

Orrick, Herrington & Sutcliffe LLP

National Bank Charters for Fintech Companies

"Technology-based products and services are the future of banking and the economy." "What excites me most about the changes occurring in financial services is the great potential to expand financial inclusion, reach...more

Morrison & Foerster LLP

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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