Money Laundering

News & Analysis as of

FinCEN Proposes Anti-Money Laundering Rules for Registered Advisers

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on August 25, 2015 proposed rules to require SEC- registered investment advisers to adopt and maintain anti-money laundering (AML) programs and to...more

FinCEN Proposes AML Program Rule for Investment Advisers

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

FinCEN Proposes Extending Anti-Money Laundering Compliance Requirements to Investment Advisers

On Tuesday, the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would require SEC-registered investment advisers, including private equity and hedge funds, to comply...more

The Fourth European Union Anti-Money Laundering Directive and Its Effects on Financial Institutions Operating in the EU

The Fourth European Union Anti-Money Laundering Directive (Fourth AML Directive), approved by the European Parliament on May 20, 2015, went into effect on June 25, 2015, repealing the 2005 Third AML Directive. Given the...more

The Looting Machine & The Modernization of Corruption

Today’ Q and A is with Tom Burgis, Investigations Correspondent at Financial Times and author of “The Looting Machine: Warlords, Oligarchs, Corporations, Smugglers, and the Theft of Africa’s Wealth”. As Tom States in his...more

The 5 Most Common AML Compliance Program Deficiencies

Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance...more

OCC Comptroller Talks Future of Financial Services, Eyes FinTech Industry

On August 7, OCC Comptroller Thomas Curry delivered remarks at the Federal Home Loan Bank of Chicago, which was hosting a conference highlighting the future of financial services. Specifically, Curry discussed innovation in...more

FinCEN Issues Final Rule Imposing Special Measure Five Against FBME Bank Ltd.

On July 23, FinCEN issued a final rule pursuant to Section 311 of the USA PATRIOT Act to impose “special measure five” against FBME Bank Ltd. (“FBME”), formerly known as the Federal Bank of the Middle East. Special measure...more

Blog: CooleyAR’s summer holiday

However, before we pack our bags it is worth reflecting on David Cameron’s recent speech in Singapore where he addressed the threat posed by corruption worldwide. We were particularly interested in his comments on how the UK...more

Federal Reserve Orders Chinese Bank to Overhaul its BSA/AML Compliance Program

On July 21, a leading China-based bank agreed to address deficiencies in connection with the BSA/AML risk management and compliance program of its New York branch office. The Agreement, entered into with the Federal Reserve...more

The Fifth Letter and Expansion of the Brazilian Corruption Scandal into the Private Sector

I recently received a review copy of the book The Fifth Letter by fellow University of Michigan grad Vivian L. Carpenter. It is a rollicking good read which touches on areas of constitutional law, inalienable rights in the...more

DOJ Announces Charges Against Two Florida Men for Operating Underground Bitcoin Exchange

On July 21, U.S. Attorney for the Southern District of New York Preet Bharara, along with the Assistant Director-in-Charge of the New York Field Office of the FBI and the Special Agent-in-Charge of the New York Field Office...more

Bitcoin Week in Review 07.20.15 – 07.24.15

Domestic Developments - Florida. Anthony Murgio and Yuri Lebedev, operators of bitcoin exchange service Coin.mx were arrested on July 21, 2015 for operating the exchange without a money transmission license. The U.S....more

Data Privacy and Passenger Name Records - MEPs Approve EU Rules With Data Protection Safeguards

Draft EU rules on sharing and protecting Passenger Name Record (PNR) data of people flying to or from the EU, were approved by the Civil Liberties Committee on 15 July 2015. Once passed into law, this data will be collected...more

Blog: A Proposal To Extend Beneficial Ownership Rules To UK Land-Holding Foreign Companies

A report published yesterday by Global Witness, alleging that an individual with ties to a former Kazakh public official owns large swathes of London, follows much recent interest in the issue of public officials owning...more

BCBS Consults on Proposed Revised Version of General Guide to Account Opening

On July 16, 2015, the Basel Committee on Banking Supervision (BCBS) issued a consultation paper on a proposed revised version of its general guide to account opening. The guide was first published in February 2003. The...more

Big sweepstakes scam artists don’t cry

According to the Edmonton Sun newspaper, Nigerian-born Richard Mmah Chukwu, a resident of Edmonton, was recently convicted of implementing a multi-million dollar sweepstakes scam. Chukwu was found guilty in the Canadian...more

Governance & Securities Law Focus: Europe Edition - July 2015

In this issue: - Financial Reporting: Commission Delegated Regulations on Equivalence of Certain Third Country National GAAPs to IFRS - Proxy Advisers: ESMA Consultation on Best Practise Principles for Voting...more

Rolling the Dice: Casinos, FinCEN and AML Compliance

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML...more

Scrutinizing Third-Party Payments

It is often hard to convince people that receiving money can be a problem. Everyone likes to receive money, especially when they are being paid for something they did. In the area of compliance priorities, companies do not...more

Top Ten International Anti-Corruption Developments for June 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month with links to primary...more

June FCPA Compliance Digest | BONUS: Global Anti-Corruption and Anti-Money Laundering News

I love writing articles where I get to discuss companies making history. PetroTiger has been exonerated from criminal FCPA prosecution by the DOJ. That’s only happened once before, in the case of Morgan Stanley....more

Business Litigation Report - June 2015

In This Issue: ..From 20 Years to Zero in Six Trial Days - Noted With Interest: ..FedEx Drivers: Employees or Independent Contractors? The Ninth Circuit Weighs in on California’s Murky “Right-to-Control”...more

Lines Crossed: From Enforcing to Breaking the Law

Silk Road was a notorious black market for narcotics that used seemingly untraceable digital currencies (i.e., Bitcoins) to facilitate illegal activities on the “dark web.” Last week, former Drug Enforcement Agency (“DEA”)...more

Corporate Investigations & White Collar Defense - June 2015

The Unfolding FIFA Scandal: Will the DOJ Show the Banks a Red Card? - Why it matters: The worldwide soccer community has for years decried the brazen corruption that permeated FIFA, international soccer’s governing...more

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