News & Analysis as of

SAR BSA/AML

Ballard Spahr LLP

Department of Treasury Issues Strategy on De-Risking

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Report Offers Weak Insight on Causation but Lists Steps that Treasury Can and Should Take - The Department of Treasury (“DOT”) recently released its first ever strategy report (the “Strategy”) on the topic of de-risking,...more

Orrick, Herrington & Sutcliffe LLP

FinCEN offers suspicious activity reporting guidance for human smuggling along U.S.- Mexico border

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

Orrick, Herrington & Sutcliffe LLP

FinCEN data reveals Russian oligarchs’ financial activity

On December 22, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis on the financial activity of Russian oligarchs. ...more

Morrison & Foerster LLP

FinCEN Looks to Regulate the Real Estate Market

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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

Morrison & Foerster LLP

Financial Services Report - Spring 2021

Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more

Bradley Arant Boult Cummings LLP

National Credit Union Administration Encourages Banking Hemp Businesses — With Some Caveats

In December 2018, Congress gave the hemp industry a significant boost by passing the 2018 Farm Bill, which legalized the cultivation and sale of hemp (i.e., cannabis with a THC content of less than .3%). The 2018 Farm Bill...more

Ballard Spahr LLP

Banking and the Marijuana Industry

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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

K&L Gates LLP

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

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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

Ballard Spahr LLP

Investment Management Update - October 2015

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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

Troutman Pepper

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

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The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

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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

K&L Gates LLP

AML Update: The Rumors Are True – FinCEN Proposes Regulations That Will Require SEC Registered Investment Advisers to Adopt an AML...

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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

McGuireWoods LLP

FinCEN Announces Caesars Penalty After Multiyear Investigation

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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 Volkov Law Group

FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers

The Volkov Law Group on

FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...more

WilmerHale

FinCEN Proposes AML Requirements for Registered Investment Advisers

WilmerHale on

The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA). The August 25, 2015...more

Katten Muchin Rosenman LLP

Anti-Money Laundering Program and Suspicious Activity Report Filing for Investment Adviser

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

Stinson - Corporate & Securities Law Blog

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

Manatt, Phelps & Phillips, LLP

DOJ Charges Operators of Unregistered Bitcoin Exchange with Failure to File SARs on Bitcoin Sales to Victims of Ransomeware

Why it matters - The AML compliance community is still wrestling to understand the full implications of an indictment filed against two men who allegedly operated a Bitcoin exchange that had not been registered as a...more

The Volkov Law Group

The 5 Most Common AML Compliance Program Deficiencies

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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

The Volkov Law Group

Ten Key Elements of an AML Compliance Program

The Volkov Law Group on

AML compliance reminds me of a classic Three Stooges scene from A Plumbing We Will Go – Curly, as one of the plumbers, continues to add pipes to a leaking bathtub, only to be surprised when the water continues to come out of...more

The Volkov Law Group

Rolling the Dice: Casinos, FinCEN and AML Compliance

The Volkov Law Group on

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

Carlton Fields

Broker-Dealers File Suspiciously Few Suspicious Activity Reports

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Speaking at an anti-money laundering (AML) conference in February, SEC Director of Enforcement John Ceresney warned attendees that broker-dealers were under-filing suspicious activity reports (SARs). He said that...more

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