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Practical Tips for Ensuring Your AML Program Withstands the Scrutiny of Regulators

First Post in a Two-Part Series - How do financial institutions get in trouble with their regulators? Recent AML enforcement actions suggest that the following two failures are at the heart of most of these actions: (1)...more

FinCEN Issues Exceptive Relief from Beneficial Ownership Rule to Certain Account Renewals

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

Just How Safe Is the SAR Safe Harbor Provision?

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

FinCEN Issues Advisory on Human Rights Abuses Enabled by Corrupt PEPs and Their Financial Facilitators

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

CFPB obtains default judgment in lawsuit against debt relief companies

The CFPB has obtained a default judgment in the lawsuit it filed in October 2017 in Maryland federal district court against two commonly-owned debt relief companies, their affiliated payment processor, and three individual...more

FinCEN’s Beneficial Ownership Rule: More Practical Tips and Answers to Frequently Asked Questions

Last year, we posted FinCEN’s Beneficial Ownership Rule: A Practical Guide to Being Prepared for Implementation regarding the Customer Due Diligence Requirements for Financial Institutions Rule (the “Beneficial Ownership...more

The Definition of a Whistleblower Under the Dodd-Frank Act is Shrinking

In a unanimous ruling on February 21, the U.S. Supreme Court narrowed the definition of a whistleblower under the Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act)....more

OFAC Increases Clarity Regarding Financial Transactions with Cuba

On November 9, 2017, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) amended the Cuban Assets Control Regulations, 31 C.F.R. part 515 (the “CACR”), with the stated intent of channeling economic...more

FinCEN Issues Latest Advisory on FATF-Identified Jurisdictions with AML/CFT Deficiencies

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

FinCEN’s Beneficial Ownership Rule: A Practical Guide to Being Prepared for Implementation

In May 2016, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its final rule on Customer Due Diligence (CDD) Requirements for Financial Institutions. ...more

Indictment of Alleged High-Profile Financier of Terror Focuses on Transactions with U.S. Businesses

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

2016 Year in Review: Money Laundering (Part Two)

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

2016 Year in Review: Money Laundering (Part One)

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

Fact Sheet Clarifies AML/BSA Enforcement Priorities

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

FinCEN Expands Targeting of High-End Cash Real Estate Transactions

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

NY DFS Finalizes Rigorous AML/BSA Regulation

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

NYDFS Finalizes AML/BSA Regulation

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

FinCEN Director Discusses Initiatives to Address Money Laundering Through Real Estate

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

FinCEN Finalizes Beneficial Ownership Identification Rules

As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more

FinCEN Imposes $650,000 Civil Penalty on Small ''Card Club'' Gaming Establishment

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

NYDFS AML Proposal Would Require Certification of Compliance

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

Delaware Changes Online, Student Privacy Protection Laws

Four pieces of legislation intended to improve online privacy and protections for Delaware residents were signed into law by Governor Jack Markell on August 7, 2015. Collectively, this legislation will impact a broad range of...more

Pharmaceutical Companies Get Off-Label Marketing Victory

Last week, a federal judge ruled that the Food and Drug Administration (FDA) cannot prohibit a pharmaceutical company from marketing its drugs for off-label uses if its claims are truthful and not misleading. This ruling,...more

DOJ Cracks Down on Cyber Criminals

The Department of Justice (DOJ) recently announced the largest coordinated international law enforcement effort ever directed at an online cyber-criminal forum. Financial institutions and other companies should consider...more

Phishing Attacks Target University Employee Payroll Information

In a recent advisory, the Research and Education Networking Information Sharing and Analysis Center (REN-ISAC) warned higher education institutions about sophisticated phishing attacks that target faculty and staff...more

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