News & Analysis as of

Foreign Banks Due Diligence

Nutter McClennen & Fish LLP

Nutter Bank Report: August 2023

A federal court has issued an order granting an injunction that delays the compliance dates for the CFPB’s final rule governing the collection of small business lending data required by Section 1071 of the Dodd-Frank Wall...more

Snell & Wilmer

New Year, New Laws – Congress Passes Major Anti-Money Laundering Act

Snell & Wilmer on

On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

Ballard Spahr LLP on

On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

Pillsbury Winthrop Shaw Pittman LLP

The United States Updates Sanctions to Combat Terrorism with New Focus on Non-U.S. Banks

As it targets terrorist groups and their finances, the U.S. Government announces potent secondary sanctions that can impede correspondent banking relationships of non-U.S. banks. A new U.S. Executive Order updates the...more

Sheppard Mullin Richter & Hampton LLP

South Korea Steps Up Oversight of Cryptocurrency Exchanges

In January 2018, the Korea Financial Intelligence Unit (“KoFIU”) and the Financial Supervisory Service (“FSS”) conducted a joint inspection of six Korean banks that provide trading accounts for cryptocurrency exchanges. The...more

McGuireWoods LLP

FinCEN Final Rule on Foreign Bank Requires Covered Financial Institutions to Take “Special Measures”

McGuireWoods LLP on

On July 22, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published in the Federal Register a final rule pursuant to Section 311 of the Patriot Act against FBME Bank Ltd. (FBME,...more

Skadden, Arps, Slate, Meagher & Flom LLP

"'Know Your Customer': OFAC Raises Due Diligence Expectations of Non-US Banks"

Since 2005, a series of very large non-U.S. banks — including ABN AMRO, Credit Suisse and ING — have paid significant penalties to U.S. authorities for processing funds transfers through the United States related to business...more

BakerHostetler

Highlights of Recently Released FATCA Regulations

BakerHostetler on

On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more

Pillsbury Winthrop Shaw Pittman LLP

Stricter Anti-Money Laundering Controls on Tap for EU Banks and Financial Companies

Financial businesses operating in the European Union will need to consider implementing stricter anti-money-laundering and anti-terrorism-financing controls or face a potential fine of up to 10 percent of their annual...more

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