News & Analysis as of September 18, 2024

Bank Secrecy Act › Russia

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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 -

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

Pillsbury Winthrop Shaw Pittman LLP on 3/15/2024

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Proposed Rule to Impose Anti-Money Laundering Requirements on Investment Advisers

K2 Integrity on 2/27/2024

On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

The Challenge of Transparency in Preventing Financial Crime: Navigating Financial Integrity in a Changing Risk Landscape

K2 Integrity on 12/20/2023

The landscape of financial crimes is constantly evolving, and the concept of transparency is being fundamentally challenged. A dynamic, innovative approach is imperative to preserve and shape the future of financial...more

Banking and Consumer Regulatory Digest - October 2023

Davis Wright Tremaine LLP on 10/16/2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

DOJ, BIS, and OFAC Issue Tri-Seal Compliance Note Consolidating Information Regarding Voluntary Self-Disclosure Policies

K2 Integrity on 8/15/2023

The U.S. Department of Justice (DOJ), the U.S. Department of Commerce’s Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) published their second Tri-Seal...more

Congress Fixes Major Hole In Treasury’s Nascent Whistleblower Program While Expanding Its Scope To Sanctions Evaders

Pietragallo Gordon Alfano Bosick & Raspanti,... on 2/16/2023

Takeaways: •The Treasury Whistleblower Program now provides for guaranteed awards of 10% to 30% of the government recovery in covered actions- •The Treasury Whistleblower Program has been expanded to include not just tips...more

In the First Use of Its Section 9714 Powers, the U.S. Treasury Designated Bitzlato as a Russian-Linked Primary Money Laundering...

Skadden, Arps, Slate, Meagher & Flom LLP on 2/7/2023

On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more

Russia Sanctions Evasion and Commercial Real Estate: An Alert

Ballard Spahr LLP on 2/1/2023

On January 25, the Financial Crimes Enforcement Network (“FinCEN”) issued an “Alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies” (the “Alert”). The Alert...more

FinCEN alert covers potential CRE investments by sanctioned Russians

Orrick, Herrington & Sutcliffe LLP on 1/27/2023

On January 25, the Financial Crimes Enforcement Network (FinCEN) issued an alert to financial institutions on potential investments in the U.S. commercial real estate sector by sanctioned Russian elites, oligarchs, their...more

Russian Oligarchs and Suspicious Financial Flows: A FinCEN Analysis

Ballard Spahr LLP on 1/4/2023

The Financial Crimes Enforcement Network (“FinCEN”) issued on December 22 a Financial Trend Analysis regarding Bank Secrecy Act (“BSA”) filings during the period of March to October 2022 (the “Report”) reflecting financial...more

FinCEN analysis of BSA filings in 2021 reveals increased number and severity of ransomware attacks

Hogan Lovells on 11/8/2022

The Financial Crimes Enforcement Network’s most recent financial trend analysis report on ransomware-related Bank Secrecy Act filings for 2021 reveals an increased number of ransomware attacks and that a substantial number of...more

[Event] Canadian Forum on Global Economic Sanctions - September 22nd - 23rd, Toronto, ON, Canada

American Conference Institute (ACI) on 8/10/2022

The Canadian Institute’s 7th Annual Canadian Forum on Global Economic Sanctions returns to Toronto in-person and via livestream on September 22-23! Join a Canadian and international faculty of government of officials,...more

FinCEN Provides Reminder About BSA Reporting Requirements

Freeman Law on 3/30/2022

FinCEN and Bank Secrecy Act Reporting - On March 7, 2022, the Financial Crime Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury alerted financial institutions “to be vigilant against efforts to...more

Recent Developments in US Sanctions and Export Controls Targeting Russia

Perkins Coie on 3/22/2022

Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

Harris Beach PLLC on 3/15/2022

With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

FinCEN Warns of Russian Sanctions Evasion Attempts and Provides Guidance for Increased Vigilance

Kramer Levin Naftalis & Frankel LLP on 3/11/2022

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) of the Treasury Department published guidance on increased vigilance for potential Russian sanctions evasion attempts. The FinCEN Alert follows the...more

Blocking Payments to Russia and Its Impact on Payments Companies and Fintechs

Troutman Pepper on 3/9/2022

On February 21, President Biden issued an executive order blocking property of certain persons, and prohibiting transactions regarding Russia’s invasion of the Ukraine. The following day, the U.S. Treasury’s Office of Foreign...more

[Virtual Conference] Navigating Russia Sanctions Complexities - September 27th, 10:00 am - 5:00 pm EDT

American Conference Institute (ACI) on 6/28/2021

Unravel the multiple layers of primary and secondary Russia Sanctions and strengthen your analytical decision-making process. The Russia sanctions landscape continues to evolve in many significant ways. ACI’s 4th...more

[Virtual Event] Navigating Russia Sanctions Complexities - November 9th - 10th, 8:30 am - 12:30 pm EST

American Conference Institute (ACI) on 10/12/2020

In light of continued demand for dedicated Russia sanctions content, ACI and C5 are delighted to hold the 3rd Navigating Russia Sanctions Complexities, this year in a virtual format. This highly anticipated event is...more

[Webinar] C5’s Virtual Berlin Forum on Global Economic Sanctions - September 14th - 16th, 1:00 pm - 5:30 pm CEST

American Conference Institute (ACI) on 9/4/2020

C5's Virtual 14th Berlin Forum on Global Economic Sanctions is next week. Navigating the rapidly changing sanctions landscape and staying compliant is hard. Don’t miss this unique opportunity to hear from the most experienced...more

Key Developments in the Prosecutions for Leaks by Government Personnel of SARs Related to Michael Cohen, Paul Manafort, Richard...

Ballard Spahr LLP on 1/17/2020

Note to Government Personnel: Don’t Disclose SARs - This week, major developments unfolded in the cases against two former federal government employees for their respective roles in disclosing Suspicious Activity Reports...more

Filling Gaps: Defending American Security from Kremlin Aggression Act of 2019 Would Expand Use of Geographic Targeting Orders

Ballard Spahr LLP on 3/1/2019

“Sanctions Bill from Hell” Targets Real Estate Deals - On February 13, 2019, Sen. Lindsay Graham (R – S.C.) introduced S.482 – the Defending American Security from Kremlin Aggression Act of 2019 (“DASKAA”), a bill intended...more

Manafort Indictment Alleges High-End International Money Laundering and Tax Fraud Involving Offshore Accounts

Ballard Spahr LLP on 10/31/2017

As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more

Still Following the Money: FinCEN, Money Laundering, and the Bank Secrecy Act

Sheppard Mullin Richter & Hampton LLP on 5/24/2017

Late last week, Congressional intelligence committees reportedly received some information from the U.S. Financial Crimes Enforcement Network (FinCEN) related to investigations into Russia’s attack on the 2016 U.S....more

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Bank Secrecy Act › Russia

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