On August 1, 2024, the Department of Justice launched its Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). Under this 3-year initiative managed by DOJ’s Criminal Division, a whistleblower may be eligible...more
8/12/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Department of Justice (DOJ) ,
Financial Institutions ,
Financial Services Industry ,
Money Laundering ,
Pilot Programs ,
Terrorist Financing Regulations ,
Whistleblower Awards ,
Whistleblower Protection Policies ,
Whistleblowers
On June 14, 2024, President Biden declared June 15th World Elder Abuse Awareness Day. In honor of the day, the Financial Crimes Enforcement Network (FinCEN) reminded financial institutions (FIs) to remain vigilant in...more
6/24/2024
/ Bank Secrecy Act ,
BSA/AML ,
Consumer Financial Products ,
Elder Abuse ,
Exploitation ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Reporting Requirements ,
Scams ,
Suspicious Activity Reports (SARs) ,
Vulnerability Assessments
The Financial Crimes Enforcement Network (“FinCEN”) recently issued a Financial Trend Analysis (“Analysis”) focusing on patterns and trends identified in Bank Secrecy Act (“BSA”) data linked to Elder Financial Exploitation...more
5/2/2024
/ Bank Secrecy Act ,
BSA/AML ,
Elder Abuse ,
Exploitation ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
New Guidance ,
Popular ,
Scams ,
Suspicious Activity Reports (SARs)
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 December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more
12/5/2019
/ Agribusiness ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Cannabis Products ,
Consumer Financial Products ,
Controlled Substances ,
Controlled Substances Act ,
Debit and Credit Card Transactions ,
Decriminalization of Marijuana ,
Deregulation ,
Farm Bill ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Hemp ,
Hemp Cultivation ,
Interstate Commerce ,
Marijuana ,
Marijuana Cultivation ,
Marijuana Related Businesses ,
New Guidance ,
OCC ,
Regulatory Oversight ,
Regulatory Requirements ,
Small Business Loans ,
Suspicious Activity Reports (SARs) ,
USDA
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
11/18/2019
/ Advisory Opinions ,
AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
Bahamas ,
BSA/AML ,
Cambodia ,
Cooperative Compliance Regime ,
Corrective Actions ,
Corruption ,
Countermeasures ,
Cross-Border Transactions ,
Due Diligence ,
Economic Sanctions ,
Failure to Comply ,
FATF ,
Federal Agency Taskforce ,
Financial Institutions ,
FinCEN ,
Foreign Banks ,
Foreign Jurisdictions ,
Ghana ,
Iran ,
Money Laundering ,
Mongolia ,
North Korea ,
Pakistan ,
Panama ,
Prohibited Transactions ,
Public Statements ,
Risk Management ,
Risk-Based Approaches ,
Suspicious Activities ,
Syria ,
Terrorist Financing Regulations ,
White Collar Crimes ,
WMD ,
Yemen ,
Zimbabwe
Testimony Supports Bill Requiring States to Collect Beneficial Ownership Information at Entity Formation -
As we have blogged, the proposed Corporate Transparency Act of 2019 (the “Act”) seeks to ensure that persons who...more
5/24/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Structures ,
FATF ,
FBI ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Limited Liability Company (LLC) ,
Money Laundering ,
OCC ,
Regulatory Burden ,
Regulatory Standards ,
Senate Committees ,
Tax Evasion ,
Transparency
In early March, the House Financial Services Committee released three proposed bills to codify many of the suggested reforms discussed during ongoing conversation among financial agencies, law enforcement, financial...more
3/29/2019
/ AML/CFT ,
Beneficial Owner ,
BSA/AML ,
Financial Crimes ,
Financial Regulatory Reform ,
Financial Services Committee ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Reporting Requirements ,
Shell Corporations ,
Transparency ,
White Collar Crimes
Congress enacted the safe harbor provision of the Bank Secrecy Act (BSA), codified at 31 U.S.C. §5318(g)(3)(A), to shield financial institutions, their officers and employees from civil liability for reporting known or...more
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
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 Financial Crimes Enforcement Network's (FinCEN) continuing efforts to address the "real estate industry's vulnerability to money laundering” were outlined by FinCEN Director Jennifer Shasky Calvery in an April 12, 2016,...more
The Financial Crimes Enforcement Network (FinCEN) announced its first enforcement action against a small “card club” gaming establishment imposing a civil penalty of $650,000. The enforcement action, announced December 17,...more