News & Analysis as of

Money Laundering FinCEN

Failure to Register with FINCEN Sustains Guilty Pleas by Virtual Currency Exchangers

by Ballard Spahr LLP on

It is a potential crime to conduct a business that exchanges virtual currency and fail to register with the Financial Crimes Enforcement Network (“FinCEN“), even if the State in which one operates does not impose a similar...more

Focusing On What Matters: Preventing Money Laundering Should Be the Shared Goal of the Government and the Cannabis Industry

Suffice it to say, the appointment of Jeff Sessions as the United States Attorney General did not remove uncertainty from the cannabis industry. How our new Attorney General will approach the industry remains unclear. Indeed,...more

A Money Laundering Nightmare: Western Union Ponies Up $770 Million to Settle with DOJ, FTC and FinCEN

by Michael Volkov on

Earlier this year, in January 2017, Western Union entered into a Deferred Prosecution Agreement with the Justice Department and the FTC, and agreed to pay $586 in forfeiture to settle anti-money laundering and consumer fraud...more

Investor Suits Follow in the Wake of Western Union Settlement of Money Laundering and Fraud Claims

by Ballard Spahr LLP on

On January 19, 2017, the Western Union Company (“Western Union” or the “Company”) entered into a deferred prosecution agreement (“DPA”) with the Department of Justice (“DOJ”), in which Western Union admitted to willful...more

European Parliament: The U.S. is a Haven for Tax Cheats and Money Launderers

by Ballard Spahr LLP on

Earlier this week, we blogged about how the United States recently declared the Philippines to be a “major money laundering country.” On the same day of our post, March 7, the European Parliament (EP) issued a Report which...more

Your Daily Dose of Financial News

by Robins Kaplan LLP on

FinCEN is extending its campaign to press title insurance companies to reveal the real buyers behind shell companies that pay cash for high-end real estate deals in select cities around the country....more

FinCEN Renewal of GTOs for High-End Cash Buyers in Six Markets

by Ballard Spahr LLP on

FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more

Bitcoin and Blockchain Technology Update: Research Paper

by Locke Lord LLP on

Locke Lord London Global Head of Cards & Payments Robert Courtneidge and Associate Charlie Clarence-Smith wrote a research paper on bitcoin and blockchain technology. Over the past few years, digital currencies have been...more

FinCEN Issues Advisory on Jurisdictions with AML/CFT Deficiencies

by King & Spalding on

The Financial Crimes Enforcement Network (“FinCEN”), an agency within the U.S. Treasury Department, has put forth an Advisory on the FATFIdentified Jurisdictions with AML/CFT (Anti-Money Laundering/Combating the Financing of...more

The Western Union DPA and the Need to Investigate One’s Own

by Ballard Spahr LLP on

The Western Union Company (“Western Union”) entered into a deferred prosecution agreement (“DPA”) on January 19th with the Department of Justice, based on alleged willful failures to maintain an effective AML program and the...more

2016 Year in Review: Money Laundering (Part One)

by Ballard Spahr LLP on

2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

State Ballot Wins Only Amplify Questions About Pot Banking

The 2016 election will be remembered not only for the memorable presidential race but also for what was effectively a national referendum on cannabis. Eight states passed laws allowing its use. Medical marijuana is now...more

De-Risking 101

by Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Spoofing, Sports and the Panama Papers: BakerHostetler Offers Mid-Year Review of Cross-Border Government Investigations and...

by BakerHostetler on

Halfway through 2016, the international community has seen a staggering variety of cross-border investigations and enforcement actions. Brexit, the release of the Panama Papers, allegations of widespread sports doping and the...more

FinCEN Proposes AML Program Requirement for Banks without a Federal Functional Regulator

by Goodwin on

FinCEN has proposed extending its anti-money laundering (AML) program requirement for banks to banks that are not subject to regulation by a federal functional regulator, including state chartered limited purpose trust...more

FinCEN Proposal Looks to Extend AML Requirements to Non-Federally Regulated Banks

On April 25, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, proposed a rule that would require all banks, regardless of whether they are subject to regulation by a...more

FinCEN Expands Targeting of High-End Cash Real Estate Transactions

by Ballard Spahr LLP on

FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more

FinCEN Tightens the Screws on Money Launderers with Additional Scrutiny of High-Value Residential Real Estate Transactions

Choice real estate markets such as New York, Miami, Los Angeles, San Francisco, San Diego, and San Antonio may offer enticing amenities like buzzing nightlife or sunny beaches, but thanks to the Financial Crimes Enforcement...more

Financial Services Weekly News - July 2016 #4

by Goodwin on

Editor's Note - What Exactly Is Bitcoin? In a case featuring a sting operation beginning with meetings in a coffee shop, ice cream store and hotel lobby and ending with the sale of bitcoins to an undercover Miami Beach...more

US Financial Crimes Enforcement Network Identifies the Democratic People’s Republic of Korea as a Jurisdiction of Primary Money...

by Shearman & Sterling LLP on

The US Financial Crimes Enforcement Network, pursuant to authority contained in the USA PATRIOT ACT, found “reasonable grounds” to conclude that the Democratic People’s Republic of Korea is a jurisdiction of primary money...more

West Coast Real Estate Update: June 2016 #1

by Holland & Knight LLP on

California Governor Proposes "Build By Right" Approval Process for Affordable Housing - Recognizing the extreme need throughout California for construction of new affordable housing units, on May 13, 2016, Gov. Jerry...more

Are You Within Reach of Anti-Money Laundering Enforcement? The Tentacles of Money Laundering Schemes Affect Real Estate Investors...

The U.S. Treasury Department has signaled the latest focus of its enforcement: real estate ventures with ties to money laundering schemes. Individual real estate investors and companies involved in luxury real estate, real...more

North Korea Designation Targets Chinese Banks (IRB No. 554)

by Bryan Cave on

On May 25, the U.S. Treasury Department issued a finding designating North Korea as a jurisdiction of “primary money laundering concern.” On the same date, Treasury, through FinCEN, issued a notice of proposed rulemaking...more

FinCEN Director Discusses Initiatives to Address Money Laundering Through Real Estate

by Ballard Spahr LLP on

The Financial Crimes Enforcement Network's (FinCEN) continuing efforts to address the "real estate industry's vulnerability to money laundering” were outlined by FinCEN Director Jennifer Shasky Calvery in an April 12, 2016,...more

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

by Holland & Knight LLP on

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

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Cybersecurity

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