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Joint Statement Clarifies Due Diligence Expectations for Politically Exposed Persons

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

Lawmakers Renew Effort to Overhaul AML Laws, Including Greater Beneficial Ownership Transparency

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

Popular Video Game Serves as a Reminder of Regulatory Risks of In-game/In-app Virtual Currencies

“V-bucks,” the in-game virtual value currency of the wildly popular video game, Fortnite, is reportedly being used to launder the proceeds of stolen credit cards....more

AML/BSA Focus by U.S. Senate Committee Testimony – From Beneficial Ownership to Cryptocurrency

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

Beyond Best Practices: Regulatory Compliance Now a Necessity in the Cryptocurrency Sector

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

SEC: Broker-Dealer Maintained AML Compliance Plan in Name Only

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

Florida Lawmakers Seek to Bring Virtual Currency into the Fold

On Monday, the state of Florida moved a step closer towards amending its money laundering statute to include the nefarious use of bitcoin and other virtual currencies. The bill, H.B. 1379, has sailed through a committee vote...more

Weighing Corporate Liability under the Alien Tort Statute: What it Means for AML/CFT Controls

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

The Philippines Now a “Major Money-Laundering Country”

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

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

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