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FinCEN Seeks Comments on Modernizing the AML/CFT Regime

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

FinCEN Solicits Comments on AML Rules for the Antiquities Trade

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

FATF Continues to Stress AML Risks From Virtual Asset Service Providers

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

Money Laundering and “Narco-Cattle Ranching”

In the rainforests of Guatemala, Honduras and Nicaragua, the fires often start when drug traffickers try to clear large swaths of land. Due to the dry bush and lack of rainfall, the flames often spread out of control, but in...more

Government Accountability Office Roundup: Recent Activity on Topics Related to Trade-Based Money Laundering and Derisking

In the past month, the Government Accountability Office (“GAO”), a non-partisan legislative agency that monitors and audits government spending and operations, has issued a series of reports urging banking regulators and...more

Two Chinese Nationals Charged with Money Laundering Over $100 Million in Cryptocurrency for North Korea

Case Sheds Light on Latest Methods to Evade Detection: “Peeling” Chains - On March 2, the U.S. government sanctioned and indicted two Chinese nationals for helping North Korea launder nearly $100 million in stolen...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

Use of Tainted Assets to Pay Attorney Fees: A Primer on the Pitfalls

On August 29, the Wall Street Journal reported (paywall) a story that other news outlets later have picked up: the Department of Justice (“DOJ”) is investigating whether Jho Low, a Malaysian businessman at the center of the...more

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