Money Laundering Compliance

News & Analysis as of

Closing Gaps? FinCEN Proposes Anti-Money Laundering Rule for Investment Advisers

After more than a decade of delay, the Financial Crimes Enforcement Network (FinCEN) of the Department of Treasury issued a notice of proposed rulemaking that would require registered investment advisers to establish...more

FinCEN Issues NPRM Establishing BSA/AML Requirements for Investment Advisers

On August 25, FinCEN issued a Notice of Proposed Rulemaking (NPRM) seeking to adopt minimum Bank Secrecy Act (BSA) and anti-money laundering (AML) standards that would be applicable to investment advisers. Under the proposal,...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 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

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

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

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

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

[Webinar] How EU Companies Can Implement & Demonstrate Effective Anti Bribery Compliance in Emerging Markets - July 9, 9:00 am EST

European companies subject to FCPA jurisdiction or comparable European jurisdictions, and doing business in emerging markets such as the BRIC nations, face a rigorous compliance standard. Firms must have compliance processes...more

The FIFA Indictments and Travel Act Prosecutions under the FCPA

While the indictments last week against 14 individuals who were members or associated with Fédération Internationale de Football Association (FIFA) did not include any alleged violations of the Foreign Corrupt Practices Act...more

Preventing the Worst: Stopping Obvious and Bold FCPA Violations by Executives

Last year, a number of corruption cases, both individual prosecutions and suits against companies, revolved around the behavior of senior executives. While third parties can often be the vehicle companies use to funnel bribe...more

Gulliver’s Travels, Truth or Fiction?

There was once a man named Gulliver who traveled widely and wrote a book about his adventures called Gulliver’s Tales. During his first voyage, Gulliver is washed ashore after a shipwreck and finds himself a prisoner of a...more

As American as Duck Soup, the Marx Brothers and Stepping In It

I am at the end of my week of Marx Brothers themed posts. As you can tell, I am a huge fan and several of you have asked which is my favorite film. Before answering I must confess that I much prefer their Paramount films to...more

Former Compliance Officer Assessed Million Dollar Penalty For Role In Company's Money Laundering Violations

Corporate officers with compliance duties, take note: you may face personal liability for your role in failing to prevent your company's violations of federal law. This new reality comes courtesy of the U.S. Department of the...more

Due Diligence and The Holy Grail — Red Flags

Compliance professionals love to bandy about the term “red flag.” It is a term with infinite meanings depending on the context. A red flag in a money-laundering context is different than a red flag in a corruption context....more

Anti-Bribery and Corruption Compliance Practices

Compliance Week published its 2014 Anti-Bribery and Corruption Benchmarking Report, a survey of over 180 executives involved in ethics and FCPA compliance and internal audit. The Survey focused on risk, dealing with third...more

Regulators Increasingly Pursue Individual Liability for Money-Laundering Violations

The Financial Crimes Enforcement Network (FinCEN), an arm of the U.S. Department of Treasury, recently fined a Miami-based money services business (MSB) and its owner $10,000 for failing to implement proper anti-money...more

Behind Royal Allegations: Leveraging the Fraud Triangle to Positively Impact Your Anti-Corruption Training

It seems that the Spanish royal family can’t do anything right these days. Recall that the initial tarnish on the family came from legal, albeit unseemly occurrences (i.e. rumors of the King’s extra-marital affairs, the...more

This Week In Securities Litigation (The week ending January 10, 2014)

The insider trading trial of former SAC Capital official Matthew Martoma opened this week in Manhattan with jury selection. The SEC announced the resignation of George Canellos, Co-director of the Division of Enforcement....more

The International Comparative Legal Guide to: Business Crime 2014 - An Overview of Business Crime in Latin America

Latin America’s “Culture of Corruption” - The notion that there is a “culture of corruption” in Latin America has led some writers to note that decades of unstable economies and turbulent politics in the region have...more

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