On February 27, FinCEN issued an alert to financial institutions on the nationwide surge in check fraud schemes targeting the U.S. mail. Mail theft-related check fraud, FinCEN explained, generally relates to the fraudulent...more
On January 13, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling along the...more
On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more
On May 26, 2020, the Financial Crimes Enforcement Network, (“FinCEN”) issued a notice in the Federal Register updating cost estimates related to compliance with filing suspicious activity reports (SARs). Under the Bank...more
Part One of a Three-Part Series - We begin this week with a three-part series on banking and the marijuana industry. States continue to pass medical and recreational use marijuana legislation despite that the fact that the...more
The Financial Crimes Enforcement Network (FinCEN) proposed to amend the Bank Secrecy Act’s (BSA) definition of “Broker or Dealer in Securities” to include funding portals in order to ensure that funding portals implement...more
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
Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more
On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more
On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more
This week the Financial Crimes Enforcement Network (FinCEN) announced a Consent Agreement that imposed an $8 million civil penalty against Desert Palace, Inc. d/b/a Caesars Palace. Caesars first disclosed the investigation in...more
The Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would require registered investment advisers to establish anti-money laundering programs and file suspicious activity reports with...more
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
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
Executives of regulated entities often lament that fulfilling compliance obligations interferes with their ability to operate their business. However, an extensive (and extended) regulator investigation with the potential for...more
Why it matters - In response to recent criticism, the Commissioner of the Internal Revenue Service (IRS) John A. Koskinen announced that the agency will adopt a “common sense” approach in how it handles funds that have...more
Addressing SIFMA’s Anti-Money Laundering (“AML”) conference Wednesday, SEC Enforcement Director Andrew Ceresney said that – when it comes to AML – the lack of red flags itself is a red flag....more