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
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
On August 8, the U.S. Department of the Office of Foreign Assets Control (“OFAC”) sanctioned “notorious” virtual currency “mixer” Tornado Cash, which allegedly has been used to launder more than $7 billion worth of virtual...more
As we blogged yesterday, OFAC has been busy. Right before OFAC designated the virtual currency exchange SUEX for allegedly facilitating ransomware payments, OFAC announced another significant but more traditional action on...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
The U.S. Attorney’s Office for the Southern District of New York announced the unsealing of a superseding indictment charging Jennifer Shah and another person for conspiring to commit wire fraud and money laundering. Shah,...more
Case Highlights Confidentiality of BSA Reporting and Continued Focus on Real Estate as Money Laundering Tool -
The Northern District of California granted summary judgment to the Financial Crimes Enforcement Network...more
DOJ Charges a U.S. Billionaire, an Alleged International Drug Conspiracy Using Chinese Bank Accounts and a Guatemalan Casino, and a Former Top Mexican Official in the “War on Drugs” -
The term “October Surprise” garnered...more
The Financial Action Task Force (FATF) recently published a report titled Virtual Assets: Red Flag Indicators of Money Laundering and Terrorist Financing. The report discusses a number of red flag indicators of suspicious...more