News & Analysis as of

Shell Corporations

New GTO covers Wire Transfers

by Foodman CPAs & Advisors on

On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New...more

The Telia FCPA Resolution, Part I

by Thomas Fox on

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

FinCEN Issues New Geographic Targeting Order for Shell Companies Purchasing High-End Residential Real Estate

In its latest effort to combat money laundering within the real estate sector, the Financial Crimes Enforcement Network (“FinCEN”) has issued a new Geographic Targeting Order (“GTO”) broadening its scrutiny of shell companies...more

FinCEN’s Revised GTOs Expand Real Estate Money Laundering Crackdown To Hawaii, Close “Wire Transfer” Loophole

by Fox Rothschild LLP on

This article is Part I of a series in which we address the U.S. government’s attempts to combat money laundering in real estate transactions. This week the Treasury Department’s Financial Crimes Enforcement Network...more

Aloha Cash Buyers: FinCEN Issues Advisory to Financial Institutions; Expands Geographic Tracking Order to Include Honolulu, Wire...

by Burr & Forman on

The Financial Crimes Enforcement Network (FinCEN) announced the revision of its Geographic Targeting Orders (GTO) Tuesday. The GTO requires title insurers to report beneficial ownership information on legal entities,...more

FinCEN Issues Revised Geographic Targeting Orders Focusing On Shell Companies Purchasing Luxury Properties In 7 Major Metropolitan...

by Fox Rothschild LLP on

Yesterday the Financial Crimes Enforcement Network (FinCEN) announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell...more

Important Polling Results from BVD Webinar on Beneficial Ownership

by Michael Volkov on

On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more

Mexico’s Energy Industry: Mexico Tender Round 2.1: Shallow Water Oil Sells Big

On June 19, 2017, the Comisión Nacional de Hidrocarburos (CNH) completed the Presentation and Opening of Bid Proposals for the First Tender of the Ronda Dos (“Round 2.1”), which was first announced on July 20, 2016. Round 2.1...more

Forfeiture Case Based on Alleged Elaborate $230 Million Russian Laundering and Fraud Scheme to Settle

by Ballard Spahr LLP on

On the eve of trial this past Friday, the government announced an agreement to settle, subject to court approval, a major civil forfeiture action in the Southern District of New York. In the case, United States v. Prevezon...more

Corporate Shell Games and KYC Requirements

by Michael Volkov on

Anti-money laundering professionals are in for a rude awakening. Know Your Customer or KYC requirements are currently kicking up a notch, and will be even more dramatic when the new FinCEN beneficial ownership regulations...more

Advertising Litigation Report: Vol. 2, No. 2 - National Advertising Division (NAD) and National Advertising Review Board (NARB)

The Colgate-Palmolive Company (Tom’s of Maine “Naturally Dry” Antiperspirant), NARB Panel Report No. 215 (Jan. 25, 2017) - A National Advertising Review Board (NARB) panel determined that the National Advertising...more

Advertising Litigation Report: Vol. 2, No. 2 - National Advertising Division (NAD) and National Advertising Review Board (NARB)

The Colgate-Palmolive Company (Tom’s of Maine “Naturally Dry” Antiperspirant), NARB Panel Report No. 215 (Jan. 25, 2017) - A National Advertising Review Board (NARB) panel determined that the National Advertising...more

AML Enforcement and Compliance Trends

by Michael Volkov on

Law enforcement focus on anti-money laundering appears to be increasing. While the last ten years has seen a marked increase in AML regulatory obligations, the new administration is likely to return to some of the more...more

How effective are the UK's primary markets? FCA reviews the effectiveness of the primary markets and proposes technical...

by Hogan Lovells on

Reviewing the structure of the UK's primary markets - The FCA is reviewing the structure of the UK's primary markets to ensure that they continue to meet the needs of investors and issuers. As part of its review, the...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

When the Wall of Secrecy Collapses

by Foodman CPAs & Advisors on

Foreign Accounts, Shell Companies, Blind Trusts, Asset Protection Trusts, Offshore Trusts, Global Citizenship and US Residency are just a few of the Terms highlighted in the mega divorce proceedings of a Palm Beach County...more

Are All Troll Cases Exceptional?

In Iris Connex, LLC, v. Dell, Inc., [2:15-cv-1915-JRG] (January 25, 2016), District Judge Gilstrap, after granting summary judgment to Dell, awarded attorneys fees, noting Dell’s arguments that Iris Connex’s claim...more

How the Yellow Submarine Informs Due Diligence Lessons From 1MDB

by Thomas Fox on

Enrichment is the theme for today’s post as it is personal and illegal enrichment which seems to be the continuing message from the 1MDB scandal involving the disgraced Malaysian sovereign wealth fund. In an article in the...more

Sorry, Apple, Assignment of ITU Applications Isn’t MAGIC

by Winthrop & Weinstine, P.A. on

Another installment of Apple surveillance: it appears the tech giant has enlisted a shell company to file trademark applications for its newest products. Problem is, they might be stuck there....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

Good-Bye to Wyatt Earp and More on 1MDB

by Thomas Fox on

Wyatt Earp died this week. Not the original Wyatt Earp who died in 1929 but the Wyatt Earp of my lifetime, who was actor Hugh O’Brian. O’Brien portrayed Earp in the long running television series Wyatt Earp which ran in the...more

Customer Due Diligence in the Post-Panama Papers Era

by Michael Volkov on

Sometimes it takes a scandal to advance a policy or law enforcement cause. The Panama Papers scandal has given new life to financial regulators around the world who seek to impose customer due diligence requirements on banks...more

Banking Through Shell Companies Just Got Harder

by Sanford Millar on

For many U.S. and non-U.S. persons access to the U.S. banking system is key to preservation of the wealth or operation of their business. Anyone looking for banking security and liquidity will maintain an account in a U.S....more

FinCEN Expands Crackdown on Real Estate Buyers

by Michael Volkov on

Building on early successes, the Financial Crimes Enforcement Network (“FinCEN”) announced new rules targeting buyers of high-end real estate properties. Earlier this year, FinCEN adopted rules focusing on high-end...more

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