Office of Foreign Assets Control FinCEN

News & Analysis as of

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

Corporate Investigations & White Collar Defense - September 2015

No Dog Days of August for the SEC—A Recap of a Busy Month - Why it matters: Who says there is a government slowdown in August? Not for the SEC. August 2015 turned out to be very busy indeed for the agency, which...more

AML and Investment Advisers: Understanding FinCEN's New Anti-Money Laundering Rules

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed rulemaking that would require registered investment advisers, including certain hedge funds and asset managers, to establish anti-money laundering...more

FinCrimes Update - July 2015 Summary Volume 2, Issue 7

AML/BSA & OFAC: OFAC PROVIDES GUIDANCE TO FINANCIAL INSTITUTIONS TO HELP COMPLY WITH CRIMEA SANCTIONS REGULATIONS - On July 30, OFAC issued a “Crimea Sanctions Advisory,” highlighting certain actions that have been...more

Red Notice Newsletter - June 2015

This month on the anticorruption front, an energy company announces the U.S. Department of Justice (DOJ) has declined to bring charges following an Foreign Corrupt Practices Act (FCPA)-related investigation, the protracted...more

AML Compliance Expectations Unabated—Fines, Enforcement Actions and a Deferred Prosecution Agreement Against Banks, Money...

Why it matters - Three Financial Crimes Enforcement Network (FinCEN) orders, three sets of fines and asset forfeitures, a deferred prosecution agreement and one bank enforcement action demonstrate the resolve of the...more

FinCrimes Update - May 2015 Summary, Volume 2, Issue 5

FINCEN NAMES JAMES EL-HINDI AS NEW DEPUTY DIRECTOR - On May 21, FinCEN announced Jamal El-Hindi as its new Deputy Director. Since January 2015, El-Hindi has been serving as the agency’s acting Deputy Director, and...more

Red Notice Newsletter - May 2015

Welcome to the May 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, a German engineering firm tests Brazil's recently implemented anticorruption...more

FinCrimes Update - April 2015 Summary, Volume 2, Issue 4

OFAC FINES PAYMENT PROCESSING COMPANY FOR PROVIDING SERVICES TO A DESIGNATED NARCOTICS TRAFFICKER - On April 15, OFAC entered into a $23,336 settlement with an Atlanta-based payment processing company for its role in...more

Beneficial Ownership and AML, Sanctions and Anti-Corruption Compliance

Sometimes compliance realities outpace enforcement and regulatory requirements. When it comes to FinCEN’s proposal to implement a beneficial ownership rule for financial institutions, global financial institutions do not need...more

FinCrimes Update - February 2015 Summary, Volume 2, Issue 2

NEW YORK BANK REGULATORY CONSIDERING CYBERSECURITY REGULATIONS, RANDOM AUDITS OF BANKS - On February 25, New York DFS Superintendent Benjamin Lawsky delivered remarks at Columbia Law School focusing on how state bank...more

FinCrimes Update - January 2015, Volumn 2, Issue 1

FINCEN FINES NY-BASED SECURITIES BROKER-DEALER FOR ANTI-MONEY LAUNDERING SHORTFALLS - On January 27, FinCEN fined a New York securities broker-dealer firm $20 million for violating the BSA. According to the press release,...more

Financial Services Weekly News Roundup - January 2015 #2

Editor’s Note - Rich Matheny Comments on New Format of OFAC Sanctions List: On January 5, OFAC announced the release of a new format of its Specially Designated Nationals and Blocked Persons (SDN) List. With the new...more

Financial Services Weekly News Roundup - December 2014 #3

Amendment to Swaps Push-out Provision of Dodd-Frank: Section 630 of the recently passed Consolidated and Further Continuing Appropriations Act, 2015 (“Omnibus Spending Bill” – see p. 249) amends Section 716 of the Dodd-Frank...more

FFIEC Releases Revised BSA/AML Examination Manual

On November 26, the Federal Financial Institutions Examination Council (FFIEC) released the revised Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. ...more

FinCrimes Update - November 2014 Summary, Volume 1, Issue 9

IN THIS ISSUE: BSA/AML & OFAC | Virtual Currency & Payment Systems | FCPA & Anti-Corruption | Criminal Enforcement. ...more

FinCrimes Update - October 2014 Summary, Volume 1, Issue 8

BSA/AML & OFAC: LESSONS LEARNED FROM ARAB BANK'S U.S. ANTI-TERRORISM ACT VERDICT On September 22, 2014, following a two-month trial, a federal jury in the Eastern District of New York ruled in favor of a group of...more

FinCrimes Update - September 2014 Summary, Volume 1, Issue 7

IN THIS ISSUE: BSA/AML & OFAC | Virtual Currency & Payment Systems | FCPA & Anti-Corruption | Criminal Enforcement. BSA/AML & OFAC: FINCEN OFFERS RED FLAGS GUIDANCE ON HUMAN TRAFFICKING AND...more

FinCrimes Update - August 2014 Summary, Volume 1, Issue 6

In This Issue: - BSA/AML & OFAC - Virtual Currency & Payment Systems - FCPA & Anti-Corruption - Criminal Enforcement - Excerpt from BSA/AML & OFAC: FINCEN PUBLISHES LONG-AWAITED...more

FinCrimes Update - July 2014 Summary, Volumn 1, Issue 5

FINCEN PROPOSES CUSTOMER DUE DILIGENCE RULE - On July 30, FinCEN released a proposed rule that would amend BSA regulations to clarify and add customer due diligence (CDD) obligations for banks and other financial...more

FinCrimes Update - Volume 1, Issue 3

On May 8, OFAC released enforcement information regarding “apparent violations” of the Cuban Assets Control Regulations by Canadian subsidiaries of a U.S. insurance company. The U.S. company self-reported 3,560 apparent...more

FinCEN Advisory Addresses Risks Presented By Citizenship-by-Investment Program

On May 20, FinCEN issued Advisory FIN-2014-A004, warning financial institutions about the risk of illicit financial activity conducted by individuals with passports from St. Kitts and Nevis (SKN), which allows individuals to...more

Two Non-U.S. Banks Agree to Pay Penalties Totaling $160 Million for Violations of U.S. Sanctions Laws Resulting from Omnibus...

Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more

2012 Bank Enforcement Actions Still High, But Significantly Lower Than 2010-11

Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013. Overall Trends & Outlook - In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more

U.S. Law Enforcement Authorities And Regulators Resolve Significant Money Laundering And Sanctions Investigations

On December 11, a major international bank holding company announced agreements with U.S. law enforcement authorities and federal bank regulators to end investigations into alleged inadequate compliance with anti-money...more

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