Terrorist Financing Regulations

News & Analysis as of

European Banking Authority Opines on Virtual Currencies and the Fourth Anti-Money Laundering Directive

The European Banking Authority published an Opinion on the Commission’s proposed amendments to the Fourth Anti-Money Laundering Directive and its application to virtual currencies. The Commission is proposing to bring...more

Why is On-boarding and Off-boarding Bank Clients Important?

After the Panama Papers, and with the recent FinCEN final Customer Due Diligence (CDD) rule, U.S. financial institutions are further focused on tightening internal controls against money laundering, terrorist financing,...more

EU Proposal to Address Virtual Currency Exchanges & Wallet Providers in Anti-Money Laundering Laws

The European Commission recently published a proposal to amend the Fourth Anti-Money Laundering Directive, the legislation that specifies the anti-money laundering, or AML, and counter terrorist financing rules for EU Member...more

EU brings virtual currency exchanges and wallet providers under the EU Anti-Money Laundering Directive

On 5 July 2016, the European Commission (the Commission) adopted a proposal for a directive that, when passed, will begin to narrow the regulatory gap between the U.S. and the EU for virtual currency exchange platforms and...more

UK Financial Regulatory Developments - July 2016 #3

CPS pursuing assets in land banking fraud case - Four directors, two of whom had already been disqualified as directors by the Financial Services Authority (now FCA), have been convicted of conspiracy to defraud,...more

UK Government Action Plan for Anti-Money Laundering and Counter-Terrorist Finance

The UK Government published an Action Plan for anti-money laundering and counter terrorism financing. The Government is aiming to overhaul the UK approach to AML and CTF by giving new capabilities and legal powers to law...more

European Banking Authority Opinion on Customer Due Diligence for Asylum Seekers

The European Banking Authority published an Opinion on the application of customer due diligence measures to customers who are asylum seekers from higher-risk third countries or territories. The Opinion, addressed to national...more

It's Tough to Be a Chief Compliance Officer Under New York's Proposed Anti-Money Laundering Rule

The proposed regulation would require covered financial institutions to maintain watch-list-filtering and transaction-monitoring programs. On December 16, 2015, the New York Department of Financial Services (NYDFS)...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

Preventing Terrorism with AML Accountability AND Budgeting

Preventing money from getting to terrorists is a chief goal of AML programs. But at a basic level an AML program is only as strong as its budget, regardless of how good the CCO is. Can we hold CCOs criminally accountable for...more

Loan to San Bernardino Attacker Generates New Focus on Online Marketplace Lending and Terrorism Financing

News that an online marketplace lender extended a $28,500 loan to Syed Rizwan Farook, one of the alleged San Bernardino attackers, just two weeks before the attack, has spurred House Financial Services Committee Chairman Jeb...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

Blog: European Council Asks Commission To Strengthen Controls Over Electronic Payments & Virtual Currencies

(As anticipated) the European Counsel has invited the Commission “to strengthen controls of non-banking payment methods such as electronic/anonymous payments, money remittances, cash-carriers, virtual currencies, … and...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

Blog: European Council To Ask Commission To Strengthen Controls Over Electronic Payments & Virtual Currencies

It’s being widely reported in Europe this evening that, after tomorrow’s extraordinary meeting of the European Union’s Justice & Home Affairs Council meeting, the European Council will ask the Europe Commission to “present...more

Treasury reports on terrorist asset freezing measures

Treasury has reported on use of terrorist asset freezing designations and frozen funds during the quarter ending September 2015. ...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

Treasury publishes ML NRA

Treasury has released its first national risk assessment (NRA) on the domestic risks of money laundering (ML) and terrorist financing within the regulated sector. This includes the risks associated with cash, new payment...more

Virtual Currencies: International Actions and Regulations

This chart is provided by Perkins Coie LLP’s Decentralized Virtual Currency industry practice group for informational purposes only and is not legal advice. This information is not intended to create, and receipt of it does...more

ECJ publishes MLD3 due diligence interpretation opinion

ECJ has published an opinion in the case of Safe Interenvíos S.A. v. Liberbank S.A. and Others. Three banks had closed accounts a payment institution held with them, on the basis of money laundering concerns. The request for...more

Treasury launches “red tape” consultation

Treasury has launched a review designed to improve the effectiveness of rules designed to prevent money laundering and terrorist financing (AML/CTF). The review forms part of Treasury’s aim to save businesses money by cutting...more

Treasury updates sanctions

Treasury has renewed designations under the Terrorist Asset Freezing etc Act 2010, and updated the sanctions lists in respect of Al-Qaida....more

FinCEN Rule Proposes AML Regulations for Registered Investment Advisers

On August 25, the Financial Crimes Enforcement Network (“FinCEN”) proposed an anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange Commission (the “SEC”). The issuance...more

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