News & Analysis as of

Know Your Customers

The Government Uses Multiple Tools to Fight Corruption

by Thomas Fox on

There are multiple ways to deal with an issue which can provide known and unforeseen benefits. Today we celebrate one of those as it was on this day in 1944, that President Franklin Roosevelt signed the GI Bill into...more

The Summons

by Moskowitz LLP on

Coinbase is a San Francisco-based cryptocurrency exchange company that operates bitcoin and other digital asset transactions and storage for over one million users in 190 countries....more

Corporate Shell Games and KYC Requirements

by Michael Volkov on

Anti-money laundering professionals are in for a rude awakening. Know Your Customer or KYC requirements are currently kicking up a notch, and will be even more dramatic when the new FinCEN beneficial ownership regulations...more

Are Banks Ready for a KYC Revolution?

Many of the world’s largest financial institutions have invested in distributed ledger technology—known popularly as blockchain technology—to improve their business operations. An area where this disruptive innovation holds...more

Financial Stability Board Publishes 2017 Plan to Address Decline in Correspondent Banking

by Shearman & Sterling LLP on

The Financial Stability Board published an updated progress report outlining its action plan to assess and address the decline in correspondent banking. Correspondent banking relationships enable banks to access financial...more

EEOC Wins Jury Verdict in Sexual Harassment Case against Costco

Failure to Intervene Against Harassing Customer Created Hostile Work Environment, EEOC Charged - CHICAGO - A federal jury has awarded $250,000 in compensatory damages to a former employee of Costco Wholesale, Inc. who...more

Basel Committee on Banking Supervision Consults on Revisions to Correspondent Banking Guidance for Money Laundering and Financing...

by Shearman & Sterling LLP on

The Basel Committee on Banking Supervision launched a consultation on proposed revisions to the correspondent banking and account opening annexes of its Committee Guidelines on sound management of risks related to money...more

New Social Payment Option Expands Reach of Bitcoin Users While Cutting Bitcoin Exchanges

by Goodwin on

Last week, Circle announced major changes to its application and platform. While many focused on Circle’s decision to cut its users’ ability to buy and sell Bitcoin, the breaking news may have been its decision to create a...more

FinCEN’s Beneficial Ownership Rule and Increased AML Burden

Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more

Upping the Ante on Casinos’ AML Compliance

FinCEN focus requires major shift in gaming business practices - Which complex, global industry where billions of dollars exchange hands every day, and where high-net-worth customers park significant sums, is facing...more

Digitizing Brick and Mortar: Geofencing and Geolocation Can Help Retailers Win at Omnichannel

by Goulston & Storrs PC on

We have blogged previously about the steady rise of e-commerce, the benefits and challenges of creating a cohesive omnichannel experience, and some of the special issues omnichannel creates for the landlord-tenant...more

EU brings virtual currency exchanges and wallet providers under the EU Anti-Money Laundering Directive

by Reed Smith on

On 5 July 2016, the European Commission (the Commission) adopted a proposal for a directive that, when passed, will begin to narrow the regulatory gap between the U.S. and the EU for virtual currency exchange platforms and...more

New Economic Opportunities with Cuba Present Financial Rewards Along with Associated Compliance Challenges

by Pepper Hamilton LLP on

The opening of Cuba to greater commercial and financial activity offers many possibilities for U.S. financial institutions but, with those possibilities, comes a responsibility to meet the complex compliance challenges that...more

European Banking Authority Opinion on Customer Due Diligence for Asylum Seekers

by Shearman & Sterling LLP on

The European Banking Authority published an Opinion on the application of customer due diligence measures to customers who are asylum seekers from higher-risk third countries or territories. The Opinion, addressed to national...more

Online Payment Systems Technology in China—Trojan Horse or Forbidden Fruit?

by Morgan Lewis on

Powerful new computational technology pioneered in e-commerce presents Chinese regulators with potential concerns and solutions to the perennial problem of information, pricing, and settlement capacity. Online payment...more

"A Long Time Coming: FinCEN Proposes AML Program and SAR Requirements for Investment Advisers"

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would impose certain anti-money laundering (“AML”) requirements on...more

SEC Takes More Time to Consider Municipal Advisor Conduct Rule

by Burr & Forman on

The SEC instituted proceedings August 6 to allow additional time – and analysis – of the MSRB’s proposed Rule G-42 establishing broad conduct standards for municipal advisors. The Order essentially buys more time for the SEC...more

Export Control Laws for the General Counsel

by Williams Mullen on

You are the chief legal officer of a U.S. company. Your CEO walks into your office and announces that your company is about to conclude its first international sale. In addition, the company has just appointed distributors in...more

Automation and AML/BSA Compliance

by Michael Volkov on

The future of compliance includes technology solutions. Do not get me wrong – technology is not a panacea but it is an important strategy for leveraging resources. In the anti-corruption and sanctions compliance arenas,...more

Your Customer Base – Part One: Know Your Customer

Operating a successful business can tax even the most resolute individual or management team. Daily issues abound – operations, human resources, IT, and product inventory. It can be all-consuming. However, whether having...more

"'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

What You Need to Know About the STOCK Act

by Holland & Knight LLP on

Beginning today, members and senior staff1 of the U.S. House of Representatives and U.S. Senate are required to disclose certain financial transactions no later than 45 days after the transaction has occurred. This new...more

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Cybersecurity

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