Summary -
Deputy Attorney General Lisa O. Monaco unveiled Wednesday, Oct. 4, the Department of Justice’s (DOJ) new safe harbor policy for voluntary self-disclosures (VSD) arising from mergers and acquisitions (Safe Harbor...more
On August 8, 2023, the American Bar Association (“ABA”) House of Delegates voted overwhelmingly (216–102) to pass Revised Resolution 100 (the “Resolution”), which in turn revised ABA Model Rule of Professional Conduct 1.16...more
On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing...more
8/14/2023
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
CFTC ,
Corporate Transparency Act ,
Digital Assets ,
FBAR ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Money Services Business ,
NDAA ,
Proposed Legislation ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC)
Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs -
On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more
8/11/2023
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Corporate Transparency Act ,
Cryptoassets ,
Cryptocurrency ,
Cyber Crimes ,
Digital Assets ,
Digital Wallets ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Money Services Business ,
Proposed Legislation ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC)
On May 19, 2023 the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) released a joint supplemental alert (the “Supplemental Alert”) concerning...more
On February 27, 2023, the Financial Crimes Enforcement Network (FinCEN) in conjunction with the United States Postal Service (USPS) issued a press release and alert concerning the “national surge in check fraud schemes...more
Indictment Alleges Use of Shell Companies, Nominees, Foreign Bank Accounts and Real Estate -
On December 7, 2022, the United States Attorney’s Office for the Eastern District of New York (“DOJ”) unsealed a seven-count...more
On September 13, the United States Attorney’s Office for the Eastern District of New York announced that defendant Hanan Ofer pleaded guilty to “failing to maintain an effective anti-money laundering program.” Ofer and his...more
On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. ...more
On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. ...more
On June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022. In the SRP, the OCC opines on its current safety and soundness concerns for banks under...more
On April 5, 2022 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced sanctions against “the world’s largest and most prominent darknet market, Hydra Market” and Garantex, a virtual...more
On February 8, 2022, the Department of Justice announced the seizure of a record $3.6 billion in stolen BTC it alleges was tied to the 2016 hack of Bitfinex, a virtual currency exchange. A husband-wife duo, Ilya “Dutch”...more
Indictment Alleges $1.6 Billion in Corrupt Contracts, Funneled Through Shell Companies and Correspondent Accounts, and Paid With Gold Sold on Behalf of Venezuela -
On October 21, 2021, a grand jury indictment was unsealed in...more
Global AML Compliance Faces Challenges Relating to Regulator Expertise, the Travel Rule, Decentralized Finance, and “Regulator Shopping”...more
European Commission Proposes EU-Level Supervisory Authority and Cryptocurrency Travel Rule -
European Banking Authority Offers New Guidelines on AML Compliance Officers -
Just as the United States has expanded...more
Agenda Highlights Intersection of National Security, Corruption and Anti-Money Laundering -
On June 3, 2021, President Biden unveiled a National Security Study Memorandum entitled Memorandum on Establishing the Fight...more
As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) contains major changes to the Bank Secrecy Act (“BSA”), coupled with other changes relating to money laundering, anti-money laundering (“AML”),...more
The Comptroller of the Currency (the “OCC”) has been busy, and focused on technology. We discuss two recent developments: proposed regulations that would allow the OCC to grant exemptions relating to Suspicious Acivity...more
On November 5, 2020, the Council of the European Union approved a new action plan to strengthen anti-money laundering and combatting terrorism financing across the EU. The Action Plan, “an Action Plan for a comprehensive...more
October is National Cybersecurity Awareness Month, and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) kicked off the month by issuing two...more
10/8/2020
/ Bank Secrecy Act ,
BSA/AML ,
Cyber Crimes ,
Cybersecurity ,
Financial Institutions ,
FinCEN ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Privacy Concerns ,
Ransomware ,
Suspicious Activity Reports (SARs)
New York State Encourages Banking for State-Licensed Medical Marijuana Businesses – Whereas a Maine Company Runs Into Trouble, Despite State Law Legalizing Medical Marijuana....more
8/16/2018
/ Anti-Money Laundering ,
BSA/AML ,
Cole Memorandum ,
Controlled Substances ,
Decriminalization of Marijuana ,
Dispensaries ,
Federal v State Law Application ,
Financial Institutions ,
Financial Services Industry ,
Financial Transactions ,
Healthcare ,
Marijuana ,
Marijuana Related Businesses ,
Medical Marijuana ,
New Guidance ,
NYDFS ,
Regulatory Standards ,
Risk Management ,
State and Local Government
The U.S. Department of Justice (DOJ) earlier this week announced that it was disbanding the Financial Fraud Enforcement Task Force, established under the Obama Administration. ...more
7/16/2018
/ Consumer Financial Products ,
Consumer Fraud ,
Department of Justice (DOJ) ,
Digital Currency ,
Elder Abuse ,
Executive Orders ,
Exploitation ,
Federal Agency Taskforce ,
Financial Crimes ,
Financial Services Industry ,
Investment Products ,
Money Laundering ,
Regulatory Oversight ,
Tribal Governments
Late last week, the Financial Conduct Authority (“FCA”), the United Kingdom’s financial services regulator, imposed a $1.2 million (896,100 pound) fine on the UK division of India’s Canara Bank, an Indian state-owned bank,...more
Last week, President Donald Trump issued an Executive Order banning “all transactions” and “dealings” by any individual or entity in the United States that involve “any digital currency, digital coin, or digital token” issued...more
3/28/2018
/ BSA/AML ,
Digital Currency ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela ,
Virtual Currency