News & Analysis as of

Corruption BSA/AML

Morrison & Foerster LLP

Corporate Whistleblower Awards Pilot Program

On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue...more

Seyfarth Shaw LLP

Court Finds Corporate Transparency Act Unconstitutional – What Should You Do?

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On March 1, 2024, the United States District Court for the Northern District of Alabama, in the case of National Small Business United v. Yellen, declared that the Corporate Transparency Act (CTA) is unconstitutional....more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

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In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

Ballard Spahr LLP

The Basel AML Index: Forfeiture, Non-Profits, Crypto, and More. A Guest Blog.

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Today we are very pleased to welcome, once again, guest blogger Dr. Kateryna Boguslavska of the Basel Institute on Governance (“Basel Institute”), who will discuss the Basel Institute’s release of the 12th annual Public...more

Thomas Fox - Compliance Evangelist

Levels of Due Diligence

Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Orrick, Herrington & Sutcliffe LLP

FinCEN offers suspicious activity reporting guidance for human smuggling along U.S.- Mexico border

On January 13, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling along the...more

StoneTurn

3 Key Takeaways from FATF’s Recent Mutual Evaluations Report

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The Financial Action Task Force (“FATF”) recently released its Report on the State of Effectiveness and Compliance with the FATF Standards (“Report”). The Report contains the results of its 4th Round of Mutual Evaluations...more

Jones Day

2021 Anti-Money Laundering and Sanctions Year in Review

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2021 was a precedent-setting year for anti-money laundering (“AML”) enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory...more

The Volkov Law Group

Prosecutors Embrace Criminal AML Charges in Corruption Cases

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Federal prosecutors enjoy flipping through the United States Criminal Code, 18 U.S.C. §§ 1 et seq., to pick out tools to charge defendants.  Over the last ten years, DOJ’s reliance on criminal charges in FCPA cases has...more

King & Spalding

FinCEN Requests Comments on Beneficial Ownership Reporting Requirement; FinCEN’s Request For Information Moves U.S. Towards...

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The United States Department of the Treasury (“Treasury”) is taking further action to combat corruption, money laundering, terrorist financing, tax fraud, and other illicit activities. Following its Advance Notice of...more

Manatt, Phelps & Phillips, LLP

The Government’s New Strategy To Counter Corruption: What You Need To Know

On June 3, 2021, the White House issued a memorandum formally establishing the fight against corruption as a core national security interest. The memorandum directed the development of a presidential strategy to, among other...more

The Volkov Law Group

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

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The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals.  ...more

Morrison & Foerster LLP

FinCEN Looks to Regulate the Real Estate Market

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On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more

Ballard Spahr LLP

White House Releases Sweeping U.S. Strategy on Countering Corruption

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Last week, the Biden Administration unveiled a sweeping “whole-of-government approach” to combating corruption. Identifying corruption as a “cancer within the body of societies—a disease that eats at the public trust and the...more

The Volkov Law Group

FINRA Reminds Broker-Dealers on Importance of Compliance with New AML Rules

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The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements.  There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will...more

McDermott Will & Emery

FinCEN Announces Anti-Money Laundering Priorities

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The Financial Crimes Enforcement Network (FinCEN) recently issued its government-wide anti-money laundering (AML) and countering the financing of terrorism (CFT) priorities (AML/CFT priorities). FinCEN issued the AML/CFT...more

Jones Day

FinCEN Issues First U.S. Priorities for Anti-Money Laundering and Counter-Terrorism Financing

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On June 30, 2021, FinCEN announced the first set of government-wide AML/CFT Priorities, as required by the Anti-Money Laundering Act of 2020 ("AML Act"). Consistent with the National Strategy for Combating Terrorist and Other...more

Hogan Lovells

Joint focus by Biden Administration and Congress points towards enhanced anti-corruption efforts

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There has been significant movement recently, by both the Biden Administration as well as Congress, to enhance the U.S. government’s ability to tackle corruption. This article provides a summary of those efforts and several...more

Cadwalader, Wickersham & Taft LLP

DOJ Casts the FCPA Spotlight on Brazil-Related Enforcement

On May 25, 2021, the U.S. Department of Justice (“DOJ”) unsealed an indictment charging two Austrian citizens, Peter Weinzierl (“Weinzierl”) and Alexander Waldstein (“Waldstein”), for their roles in a scheme to launder...more

K2 Integrity

Federal Agencies Clarify Application of Model Risk Management Guidance to BSA/AML Compliance and Request Information from Industry

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On April 9, 2021, U.S. federal regulators issued an Interagency Statement addressing the application of existing model risk management guidance (MRMG) to systems or models used by banks to comply with Bank Secrecy Act (BSA)...more

The Volkov Law Group

Biden Administration Ramping Up Anti-Corruption Effort

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The Biden Administration is taking over the reins of government with vigor and focus. The Department of Justice, the Treasury Department, the State Department and the Commerce Department are expected to coordinate closely in...more

Orrick, Herrington & Sutcliffe LLP

The Anti‐Money Laundering Act of 2020

On January 1, 2021, Congress enacted a broad range of anti-money laundering (“AML”) reforms within the Anti-Money Laundering Act of 2020 (the “AML Act”), as part of the National Defense Authorization Act for Fiscal Year 2021...more

K2 Integrity

FATF Plenary Outcomes: October 21-23, 2020

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Beginning on October 21, 2020, the Financial Action Task Force (“FATF”) held its three-day Plenary meeting virtually. It was the first Plenary of Germany’s two-year Presidency. As part of the Plenary outcomes, the FATF...more

Orrick, Herrington & Sutcliffe LLP

CFTC Enforcement Actions and Decisions of Note: CFTC Begins AML Enforcement

The CFTC recently joined the host of other federal and state regulators who enforce anti-money laundering laws, by bringing three cases finding violations of CFTC Regulation 42.2. Regulation 42.2 requires futures commission...more

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