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
FinCEN’s recent preliminary rulemaking aims to enhance and modernize regulations with requirements and priorities that affect a broad range of “financial institutions” across industries—but lacks concrete guidance on...more
7/26/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Chevron Deference ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Popular ,
Regulatory Agenda ,
Risk Assessment ,
Terrorist Financing Regulations
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)
The Financial Crimes Enforcement Network (“FinCEN”) recently complied with two important deadlines under the Anti-Money Laundering Act (“AML Act”) — issuing national priorities for AML and countering the financing of...more
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
FinCEN Cites Low Risk of Money Laundering and High Regulatory Burden of Rule -
On September 7, 2018, the Financial Crimes Enforcement Network (“FinCEN”) issued permanent exceptive relief (“Relief”) to the Beneficial...more
9/17/2018
/ Bank Secrecy Act ,
Beneficial Owner ,
Consumer Financial Products ,
Due Diligence ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Know Your Customers ,
Money Laundering ,
Regulatory Burden ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
On June 12, 2018, FinCEN issued an “Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators” to highlight the connection between corrupt senior foreign political...more
6/19/2018
/ Corruption ,
Exploitation ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Foreign Official ,
Human Rights ,
Money Laundering ,
Offshore Companies ,
PEP ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
White Collar Crimes
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
On March 24, 2017, the U.S. Department of Justice unsealed an indictment charging Kassim Tajideen, an alleged prominent financial supporter of the Hizballah terror organization, with evading U.S. sanctions and conspiring to...more
3/31/2017
/ AML/CFT ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Fraudulent Wire Transfers ,
Hizballah ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Terrorism Funding ,
Terrorist Financing Regulations
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
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 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