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
In Related Case, Federal Court Holds that Bitcoin-to-Bitcoin “Tumbler” Can Represent “Money Transmission”
On April 27, IRS CI and FBI Special Agents arrested Roman Sterlingov, a dual citizen of Russia and Sweden, for his...more
On December 18, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposal to impose on banks and money service businesses (“affected institutions”) a new set of rules for digital currency transactions involving...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
FinCEN Director Kenneth A. Blanco delivered prepared remarks on September 24 at the 2019 Federal Identity (FedID) Forum and Exposition in Tampa, Florida. Director Blanco summarized the topics of his remarks by stating the...more
9/27/2019
/ Acting Directors ,
Authentication ,
Bank Secrecy Act ,
Business E-Mail Compromise (BEC) ,
Cyber Policies ,
Cybersecurity ,
FinCEN ,
Hackers ,
National Security ,
Personally Identifiable Information ,
Popular ,
Suspicious Activity Reports (SARs)
The Issue of Who Truly Runs and Owns Entities Contines to Gnaw at Congress and Law Enforcement -
First Post in a Two-Post Series on the ILLICIT CASH Act -
On June 10, a bipartisan group of lawmakers in the U.S. Senate...more
6/20/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Regulatory Requirements ,
Transparency
First Post in a Two-Part Series -
On December 11, Judge Denise Cote of the Southern District of New York granted, in part, the Securities and Exchange Commission’s (“SEC”) motion for summary judgement in its action against...more
12/21/2018
/ Bank Secrecy Act ,
Books & Records ,
Broker-Dealer ,
Clearing Agents ,
Enforcement Actions ,
Enforcement Authority ,
Financial Services Industry ,
First Impression ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Stock Trades ,
Suspicious Activity Reports (SARs)
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
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
On June 5, the SEC filed suit against Salt Lake City-based Alpine Securities, Corp. (“Alpine”). The complaint, filed in the Southern District of New York, alleges that the broker-dealer ran afoul of AML rules by “routinely...more
The Supreme Court granted certiorari on April 3 to decide whether Jordan-based Arab Bank may be liable for claims including allegations that its New York branch processed transactions for known terrorists. While the central...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