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FinCEN Director Blanco Addresses “Cyber Hygiene”

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

Court Decision Reinforces SAR Obligations of Penny Stock Clearing Brokers

Second Post in a Two-Part Series - Opinion Stresses Importance of Narrative Sections and Supporting Documentation for SARs - In our first post in this series, we discussed the Securities and Exchange Commission’s...more

Clearing Broker Continues to Take Aim at SEC’s Ability to Enforce the BSA

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

FinCEN Employee Charged with Unlawful Disclosure of SARs to Reporter

Charges Represent First Criminal Case Based Solely on Alleged Unauthorized SAR Disclosure - On October 17, the U.S. Attorney for the Southern District of New York (“SDNY”) announced the arrest of a senior employee at the...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

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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