The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more
12/8/2023
/ AML/CFT ,
Anti-Money Laundering ,
Cryptocurrency ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Hamas ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Popular ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
Terrorist Financing ,
Terrorist Financing Regulations ,
U.S. Treasury ,
Virtual Currency
The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more
10/9/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Whistleblowers
In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more
7/21/2023
/ Administrative Law Judge (ALJ) ,
Anti-Money Laundering ,
Banking Examinations ,
BSA/AML ,
Employee Misconduct ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Money Laundering ,
OCC ,
Popular ,
Rabobank ,
White Collar Crimes
On June 5, 2023, the SEC filed an extensive civil complaint against Binance Holdings Limited, its assorted affiliates and its beneficial owner and CEO, Changpeng Zhao, alleging multiple violations of the Securities Act of...more
Report Previews Potential Implications for the United States -
The European Commission (“Commission”) recently released its 2022 Supranational Risk Assessment Report (“SNRA Report”) to the European Parliament and Counsel...more
The New York State Department of Financial Services (“NYDFS” or “the Department”) published a press release on February 24, 2022 announcing the issuance of a Consent Order (“the Consent Order”) to the National Bank of...more
Third Post in a Series on the FATF Plenary Outcomes -
This blog is the third post on the Financial Action Task Force (“FATF”) fourth Plenary, an event where delegates were invited from around the world to (virtually) meet...more
Today we are very pleased to welcome guest blogger Tess Davis, who is the Executive Director of the Antiquities Coalition. Tess, a lawyer and archaeologist by training, oversees the organization’s work to fight cultural...more
First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more
Is Art an “Ideal Playing Ground” for Money Laundering?
Last week, the Permanent Subcommittee on Investigations for the U.S. Senate released a detailed, 147-page report titled “The Art Industry and U.S. Policies That...more
8/6/2020
/ AMLD V ,
Anti-Money Laundering ,
Art Auctions ,
Art Dealers ,
Art Sales ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Due Diligence ,
EU ,
Financial Institutions ,
Financial Regulatory Reform ,
Fine Art ,
Paintings Sculptures and Engravings ,
Proposed Legislation ,
Suspicious Activity Reports (SARs)