Terrorism Funding

News & Analysis as of

BCBS Finalizes Revised General Guide to Account Opening

On February 4, the Basel Committee on Banking Supervision (“BCBS“) published a revised draft of its guidelines on “sound management of risks related to money laundering and financing of terrorism” which comprises the...more

Orrick's Financial Industry Week in Review

Financial Industry Developments - FHFA, Fannie Mae and Freddie Mac Announce Independent Dispute Resolution Program - On February 2, the Federal Housing Finance Agency (the "FHFA") announced that Fannie Mae and...more

European Commission Releases Fact Sheet on Plan to Strengthen the Fight Against Terrorist Financing

On February 2, the European Commission issued a fact sheet regarding its plan to strengthen the fight against terrorist financing, posing and answering questions on topic areas including, but not limited to: (i) the measures...more

U.S. and China Sign Financial Intelligence Cooperation Memorandum

The U.S. Financial Crimes Enforcement Network (FinCEN) and the China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC) recently signed a Memorandum of Understanding (MOU) to create a “framework to facilitate...more

Second Circuit Panel Declines to Abandon Rule on Corporate Liability Under Alien Tort Statute

On December 8, 2015, the U.S. Court of Appeals for the Second Circuit (“Second Circuit”) issued its decision in In re Arab Bank, PLC Alien Tort Statute Litigation, which involved claims brought against Arab Bank, PLC (“Arab...more

New York Anti-Terror Rules Place Chief Compliance Officers in the Hot Seat

In early December 2015, New York state proposed rules to aid in the fight against terrorism by making it increasingly difficult for terrorist and other criminal organizations to transfer funds globally. As a result of several...more

Basel Committee consults on financial inclusion

The Basel Committee has issued a consultation on proposed guidance for the regulation and supervision of institutions relevant to financial inclusion. The guidance examines the risks presented by banks and non-bank financial...more

FATF reports terrorist finance action

FATF has reported on the outcome of three days of meetings, focused on combatting the financing of ISIL, their affiliates, and other terrorist groups. ...more

FinCEN Announces MOU with China Anti-Money Laundering Monitoring and Analysis Center

On December 11, FinCEN announced that Director Jennifer Shasky Calvery and the China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC) Director-General Luo Yang of the People’s Republic of China signed an MOU “to...more

The Oman Update - Official Gazette 1127

Ministerial Decisions - Ministry of Commerce & Industry - Ministerial Decision No. 315/2015 Giving Effect to the Implementing Regulations of the GCC Unified Law of Anti-dumping, Countervailing Measures &...more

U.S. and Chinese Financial Intelligence Units Sign MOU

On December 11, 2015, the Directors of the U.S. Financial Crimes Enforcement Network (FinCEN) and the China Anti-Money Laundering Monitoring and Analysis Center (CAMLMAC), signed a Memorandum of Understanding (MOU) that...more

FinCrimes Update - November 2015 Summary, Volume 2, Issue 9

FINCEN DIRECTOR HIGHLIGHTS THE SIGNIFICANCE OF SAR FILINGS - On December 9, FinCEN Director Calvery highlighted at a joint FBIIC-FSSCC meeting the role of FinCEN in gathering and analyzing financial intelligence and the...more

Council reports on ECOFIN outcome

The Council published notes from its ECOFIN meeting. Among the matters it discussed were: - progress towards the Financial Transactions Tax...more

Alien Tort Case Development: Still No Corporate Liability in the Second Circuit (At Least for Now)

On December 8, the Second Circuit Court of Appeals upheld the dismissal of plaintiffs’ claims in five consolidated cases against Arab Bank, PLC. Plaintiffs in each of the cases alleged that they, or their family members, had...more

Crowdfunding – Old-Fashioned Potato Salad or New-Fangled Money Laundering Tool?

Have you ever been depressed when a Kickstarter project to make potato salad proceeded to rake in more than your annual salary? Felt a sense of despair as an Indiegogo campaign to develop an X-rated card game went on to...more

Anti-Money Laundering Update: HM Treasury Advisory Notice on Money Laundering and Terrorist Financing Controls

On November 12, HM Treasury published an advisory note on money laundering and terrorist financing controls in jurisdictions outside the European Union. The advisory note identifies that on October 23, the Financial Action...more

Treasury updates ML advisory

Treasury has updated its advisory on money laundering (ML) and terrorist financing controls in overseas jurisdictions. It continues to advise that North Korea, Iran and Myanmar are high risk, and firms should apply enhanced...more

FATF updates on terrorist finance

FATF has updated G20 on its members’ laws to prevent terrorist finance. It conducted a survey of 194 jurisdictions to assess the extent to which their laws made it a criminal offence to finance terrorism, and whether they use...more

FSB reports on correspondent banking

FSB has published a report to G20 on actions taken to assess and address the decline in correspondent banking. It claims correspondent banking is essential for individuals, businesses and banks themselves. The report updates...more

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

FATF reports on emerging terrorist financing risks

FATF has published its report on emerging terrorist financing risks. It provides an overview of the various financing mechanisms and financial management practices used by terrorists and terrorist organisations. ...more

FATF updates guidance

FATF has published the outcomes of its plenary meeting in Paris. The main issues dealt with by this plenary were: - combating terrorist financing, which remains the top priority for FATF...more

European Supervisory Authorities Consult on AML-CFT Guidelines

On October 21, the joint committee of the three European Supervisory Authorities (ESAs, comprising the European Banking Authority, the European Securities and Markets Authority, and the European Insurance and Occupational...more

Joint Committee of ESAs Consults on Risk-Based Supervision and Risk Factors Guidelines

On October 21, 2015, the Joint Committee of the European Securities and Markets Authority, the European Banking Authority and the European Insurance and Occupational Pensions Authority (together, the European Supervisory...more

ESAs consult on AML/CTF

The European Supervisory Authorities (ESMA, EBA and EIOPA jointly) have launched a public consultation on two anti-money laundering and countering the financing of terrorism (AML/CFT) guidelines, to be made under the fourth...more

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