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Risk Assessment Money Laundering BSA/AML

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Ballard Spahr LLP

BSA Filings and Their Utility to Law Enforcement:  An Industry Viewpoint

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In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Ballard Spahr LLP

South Dakota Regulator Requires BSA/AML Compliance for Money Lender Licensees and Non-Residential Mortgage Lenders

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The South Dakota Division of Banking issued a Memorandum notifying all licensed money lenders and non-residential mortgage lenders of their Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) obligations under a 2020 Final...more

Ballard Spahr LLP

Changes to Data Collection for OCC’s Money Laundering Risk System

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On September 8, the Office of the Comptroller of the Currency (“OCC”) published an extension of its notice and request for comment (the “Notice”) in the Federal Register regarding changes to the OCC’s Money Laundering Risk...more

StoneTurn

3 Key Takeaways from FATF’s Recent Mutual Evaluations Report

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The Financial Action Task Force (“FATF”) recently released its Report on the State of Effectiveness and Compliance with the FATF Standards (“Report”). The Report contains the results of its 4th Round of Mutual Evaluations...more

BCLP

FCA’s thinly veiled warning to challenger and traditional retail banks over financial crime risk

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On 22 April 2022, the FCA published the findings of its review of financial crime controls at six relatively new and primarily digital challenger banks that all offer similar products to traditional retail banks. These six...more

WilmerHale

2021 AML Trends and Developments

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Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Seeks Public Comment on Proposed Changes to Regulations Enforcing the Bank Secrecy Act

Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more

Foodman CPAs & Advisors

Are Banks Implementing BSA Risk Based Adjustments related to COVID-19 circumstances?

The Office of the Comptroller of the Currency (OCC) Semiannual Risk Perspective Report highlights how the Covid-19 Pandemic has elevated  operational risks for banks as they are challenged with the implementation of new...more

White & Case LLP

FinCEN and US Federal Banking Agencies Clarify Risk-Based Obligations on Politically Exposed Persons

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The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more

K2 Integrity

Post-COVID Banking: Now is the Time to Make the Enterprise-Wide Risk Assessment Process Match the Rapidly Evolving Risk...

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Financial institutions have long suffered from the twin problems of high transaction-monitoring alert volumes and incomplete or low-quality data. Even before the COVID-19 pandemic, these challenges posed a constant risk to...more

Ballard Spahr LLP

Trade-Based Money Laundering: GAO Report Stresses Enforcement Challenges

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On January 29, 2020, the U.S. Government Accountability Office (GAO) publicly released the results of a study which the GAO conducted on trade-based money laundering, or TBML, entitled “Countering Illicit Finance and Trade:...more

Foodman CPAs & Advisors

Who are you partnering with for your Financial Institution’s BSA/AML Independent Testing?

Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more

Ballard Spahr LLP

AMA Updates AML Best Practices for AML Compliance

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AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more

Ballard Spahr LLP

FATF Issues Best Practices Guidance on Beneficial Ownership Information

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As we blogged yesterday, the issue of the beneficial ownership of entities and the potentially pernicious role of shell companies in perpetuating money laundering is the primary anti-money laundering (“AML”) concern across...more

Ballard Spahr LLP

Joint Statement Issued by Federal Banking Agencies Highlights Importance of Banks’ Risk-Assessments

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On July 22, 2019, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency and the U.S....more

Ballard Spahr LLP

Update: Government Enforcement in the Cryptocurrency Space

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First Post in a Two-Part Series - Recent actions in the crypto realm demonstrate that authorities and regulators have not slackened their commitment to applying and enforcing Anti-Money Laundering (“AML”) laws and...more

Ballard Spahr LLP

OCC Report: Same Threats, Different Season

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OCC Identifies AML/BSA and Cyber Threats as Elevated Risks Facing Banks - Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses...more

The Volkov Law Group

AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions

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Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations.  With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more

The Volkov Law Group

Anti-Money Laundering Risks for Global Companies (Part I of III)

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Non-financial institution companies operating in the global marketplace face ever-increasing risks of money laundering. Sophisticated criminal organizations have developed their own mechanisms and strategies to skirt money...more

Thomas Fox - Compliance Evangelist

What Days of the Week Present the Biggest Corruption Risks?

There are many different types of risk that an entity may face. However I confess I had rarely thought about a day of the week as a risk until I read a story on the Wall Street Journal (WSJ), by Syed Zain Al-Mahmood and Cris...more

Davis Wright Tremaine LLP

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

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