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)
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 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
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
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
As we blogged earlier this week, Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), in committee in the Senate. The CTIFA proposes the most substantial overhaul to the Bank...more
1/25/2018
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
Financial Regulatory Reform ,
Information Sharing ,
Legislative Agendas ,
Money Laundering ,
Patriot Act ,
Proposed Legislation ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
PANA Issues Recommendations to European Parliament: Tougher Enforcement, Greater Transparency, Improved Information Sharing and Prohibitions Against Outsourcing of Customer Due Diligence....more
10/27/2017
/ Banking Sector ,
BSA/AML ,
Customer Due Diligence (CDD) ,
EU ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Offshore Funds ,
Panama Papers ,
Popular ,
Regulatory Oversight ,
Suspicious Activity Reports (SARs) ,
Tax Avoidance ,
Tax Evasion