On December 14, the Financial Crimes Enforcement Network (“FinCEN”) issued a request for information (“RFI”), seeking comment on ways to “streamline, modernize, and update” the anti-money laundering (“AML”) and...more
On September 23, the Financial Crimes Enforcement Network (“FinCEN”) issued an advance notice of proposed rulemaking (“ANPRM”) to solicit comment on questions related to the implementation of anti-money laundering (“AML”)...more
Fourth and Final Post in a Series on the FATF Plenary Outcomes -
As we have previously blogged, the Financial Action Task Force (“FATF”) held its fourth Plenary on June 21-25, inviting delegates from around the world to...more
Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors -
On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more
9/4/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Customer Due Diligence (CDD) ,
FATF ,
Financial Institutions ,
FinCEN ,
Joint Statements ,
Politically Exposed Person (PEPs) ,
Risk-Based Approaches
On August 6, the U.S. Court of Appeals for the District of Columbia kept in place $50,000-per-day fines on three Chinese banks—whose identities are redacted—for refusing to comply with subpoenas issued by the Department of...more
8/9/2019
/ Anti-Money Laundering ,
Appeals ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
Financial Records ,
Financial Transactions ,
Foreign Banks ,
Money Laundering ,
National Security ,
North Korea ,
Patriot Act ,
Subpoenas
On April 15, the UK Treasury released proposed steps, entitled a “consultation,” to adopt the EU’s Fifth Money Laundering Directive (“5AMLD”) into national law, while also seeking comments and evidence from stakeholders to...more
4/23/2019
/ Anti-Money Laundering ,
Corruption ,
EU Directive ,
Landlords ,
MLD4 ,
MLD5 ,
Real Estate Investments ,
Real Estate Market ,
Real Estate Transactions ,
UK ,
White Collar Crimes
Critics Bemoan Removal of Potential Weapon Against Shell Companies -
Last week, and on the eve of a scheduled markup of the original bill in the House Financial Services Committee, a new draft of the Counter Terrorism and...more
6/21/2018
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Customer Due Diligence (CDD) ,
Deregulation ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Proposed Legislation ,
Reporting Requirements ,
Transparency
On February 23, the Financial Action Task Force (“FATF”) signaled that the inter-governmental body “will step up its efforts in monitoring the use of cryptocurrencies in money laundering.” ...more
3/2/2018
/ Anti-Money Laundering ,
Banking Sector ,
Bitcoin ,
Cryptocurrency ,
Digital Currency ,
FATF ,
G20 ,
Initial Coin Offering (ICOs) ,
Money Laundering ,
Regulatory Oversight ,
Risk Management ,
Token Sales ,
Virtual Currency
This week, the U.S. Senate Committee on the Judiciary and the U.S. Senate Committee on Banking, Housing and Urban Affairs held hearings focused in part on Anti-Money Laundering (“AML”) and the Bank Secrecy Act (“BSA”)....more
2/8/2018
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Bitcoin ,
BSA/AML ,
Cryptocurrency ,
Digital Currency ,
Financial Services Industry ,
Initial Coin Offering (ICOs) ,
Know Your Customers ,
Money Services Business ,
Popular ,
Securities Violations ,
Senate Banking Committee ,
Testimony ,
Token Sales ,
Trading Platforms ,
Virtual Currency
As the value of bitcoin continues to soar (USD:BTC this past weekend exceeded $19,000.00:1), we thought that now would be a good time to emphasize the need to ensure regulatory compliance with the many federal and state AML...more
12/22/2017
/ Anti-Money Laundering ,
Bitcoin ,
BitLicense ,
BSA/AML ,
Cryptocurrency ,
Digital Currency ,
Financial Services Industry ,
FinCEN ,
Know Your Customers ,
Money Services Business ,
Virtual Currency
We previously have observed that financial institutions face an increasing risk that alleged Anti-Money Laundering (“AML”) and Counter-Terrorism Financing (“CTF”) violations will lead to follow-on allegations of securities...more
The Philippines has been identified by the U.S. as a “major money-laundering country” in the 2017 International Narcotics Control Strategy Report (“Report”), published this month. The country now joins 87 others as one “whose...more
Despite the staggering $8 billion figure estimated to be spent on global compliance in 2017, U.S.-based rules regarding Anti-Money Laundering (“AML”) and Combating the Financing of Terrorism (“CFT”) remain anchored in their...more
2/22/2017
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
Blockchain ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Financial Institutions ,
Money Laundering ,
Technology ,
Terrorism Funding ,
Terrorist Financing ,
Terrorist Financing Regulations ,
Virtual Currency
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