On July 1, 2024, the Supreme Court issued its opinion in Corner Post, Inc. v Board of Governors of the Federal Reserve System in which the Court determined when a Section 702 claim under the Administrative Procedure Act (APA)...more
7/5/2024
/ Administrative Procedure Act ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corner Post Inc v Board of Governors of the Federal Reserve System ,
Debit Cards ,
Federal Reserve ,
Final Rules ,
Financial Crimes ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Interchange Fees ,
Regulation II ,
SCOTUS ,
Securities and Exchange Commission (SEC) ,
Statute of Limitations
The report examines the vulnerabilities in DeFi, including potential gaps in the United States’ Bank Secrecy Act/anti-money laundering regulatory, supervisory, and enforcement regimes for DeFi. We first discuss how Treasury...more
6/22/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Enforcement Actions ,
Office of Foreign Assets Control (OFAC) ,
Policies and Procedures ,
Risk Mitigation ,
State Regulators ,
U.S. Treasury
With the recent announcement by the U.S. Department of Justice (DOJ) that it had settled separate lawsuits against two small banks charged with facilitating consumer fraud through their relationships with third-party payment...more
The Financial Crimes Enforcement Network (FinCEN) has issued two rulings regarding the status of virtual currency miners and investors as money service businesses (MSB) under the Bank Secrecy Act (BSA). The rulings address...more
HSBC Holdings, London, and two of its U.S. subsidiaries have been ordered to pay a record $1.92 billion in fines and penalties for anti-money laundering (AML) and Office of Foreign Assets Control (OFAC) violations....more