Much has occurred in the last two months regarding the relationship between financial institutions and Marijuana-Related Businesses, or MRBs. In this post, we discuss three major developments, all of which share a complex...more
In its most recent Marijuana Banking Update, the Financial Crimes Enforcement Network (FinCEN) stated that the decline in the number of banks and credit unions actively banking marijuana-related businesses (MRBs) in the...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
Regulators Provide Greater Transparency into BSA/AML Enforcement Process. On August 13, 2020, the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more
8/27/2020
/ Banking Sector ,
BSA/AML ,
Compliance ,
Enforcement Actions ,
Federal Bank Regulatory Agencies ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Internal Controls ,
Joint Statements ,
Transparency
Regulators Provide Greater Transparency into BSA/AML Enforcement Process -
On August 13, 2020 the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more
8/24/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Cease and Desist Orders ,
Compliance ,
Criminal Investigations ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
Internal Controls ,
Joint Statements
On September 15th, FinCEN issued its latest “Advisory on FATF-Identified Jurisdictions with AML/CTF Deficiencies.” The FATF, or the Financial Action Task Force, is a 37-member intergovernmental body, including the United...more
9/20/2017
/ AML/CFT ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Due Diligence ,
FATF ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Regulatory Standards ,
Risk Management ,
Terrorist Financing
In May 2016, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its final rule on Customer Due Diligence (CDD) Requirements for Financial Institutions. ...more
In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more
2/7/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
Bitcoin ,
BSA/AML ,
Civil Forfeiture ,
Currency Transaction Reports (CTR) ,
Digital Currency ,
Financial Institutions ,
Forfeiture ,
Money Laundering ,
Virtual Currency
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
2/3/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Casinos ,
Consumer Lenders ,
Customer Due Diligence (CDD) ,
FATF ,
Financial Institutions ,
FinCEN ,
Fines ,
Gambling ,
Gaming ,
Geographic Targeting Order ,
Money Laundering ,
Mortgage Lenders ,
Mortgages ,
NYDFS ,
Offshore Funds ,
Panama Papers ,
Popular ,
Real Estate Market ,
Suspicious Activity Reports (SARs) ,
Tax Evasion
The U.S. Department of the Treasury and four U.S. federal banking regulators have issued the "Joint Fact Sheet on Foreign Correspondent Banking" in an effort to clarify enforcement priorities regarding Anti-Money Laundering...more
9/2/2016
/ AML/CFT ,
Anti-Money Laundering ,
Banking Sector ,
Banks ,
BSA/AML ,
Depository Institutions ,
Due Diligence ,
Foreign Correspondent Banking ,
Foreign Financial Institutions (FFI) ,
International Monetary Fund ,
U.S. Treasury
FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more
8/5/2016
/ Banking Sector ,
Beneficial Owner ,
Cash Transactions ,
Covered Transactions ,
FinCEN ,
Geographic Targeting Order ,
Insurance Industry ,
Money Laundering ,
Real Estate Investments ,
Real Estate Market ,
Reporting Requirements ,
Title Insurance
The New York Department of Financial Services (DFS) has finalized a new regulation setting forth rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and...more
7/11/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Financial Institutions ,
Financial Regulatory Reform ,
Foreign Banks ,
Lenders ,
Money Laundering ,
Money Transmitter ,
Mortgages ,
New Regulations ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Transaction Monitoring
The New York Department of Financial Services (DFS) has finalized a new regulation setting rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and Bank...more
7/6/2016
/ Anti-Money Laundering ,
Banking Sector ,
BSA/AML ,
Certificates of Compliance ,
Disclosure Requirements ,
Financial Institutions ,
Foreign Banks ,
Money Transmitter ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Reporting Requirements ,
Senior Managers ,
Transaction Monitoring
The New York Department of Financial Services (DFS) has proposed new regulations setting forth minimum standards for anti-money laundering (AML) transaction monitoring and filtering systems. The regulations, proposed December...more