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Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

EDNY Upholds Money Laundering Charge Against Defense Attack Under Ciminelli

In United States v. An, et al., 22-cr-640 (KAM) (E.D.N.Y. May 7, 2024), the Eastern District of New York recently addressed and rejected an argument by defendants that Ciminelli v. United States required dismissal of money...more

Treasury Asks the Eleventh Circuit to Uphold the CTA and Congressional Authority

We previously blogged on the lawsuit filed by the National Small Business Association (“NSBA”) and one of its individual members, which sought to challenge the constitutionality of the Corporate Transparency Act (“CTA”). Most...more

The American Front in Russia’s War on Ukraine: DOJ’s “Task Force KleptoCapture” Continues Focus on Operations of Sanctioned...

We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more

SEC Exam Priorities Target AML

Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more

Mum’s the Word: Pegasystems Reminds Companies to Think Hard Before Denigrating Pending Claims

Summary - A recent ruling on a motion to dismiss in a shareholder putative class action, brought by an investor against software company Pegasystems (Pega) in the District of Massachusetts, should give legal leaders and...more

Crypto Couple Plead Guilty to Money Laundering Conspiracy

In February 2022, we blogged on the seizure of a record $3.6 billion in stolen Bitcoin (“BTC”) and an accompanying criminal complaint, charging husband and wife Ilya “Dutch” Lichtenstein and Heather “Razzlekhan” Morgan with...more

Will Ciminelli’s Impact on Wire Fraud Cases Ripple Out to Bank Fraud?

In January, we blogged on the Southern District of New York sentencing of Danske Bank to three years of probation and a forfeiture of $2.059 billion. As we noted at the time, the bank was charged with bank fraud, rather than...more

Countering Financial Flows From the Illicit Trade in Fentanyl and Synthetic Opioids

We previously blogged on an advisory issued by FinCEN alerting financial institutions to the various financial mechanisms used by traffickers of fentanyl and synthetic opioids to launder the burgeoning proceeds of their...more

Civil Complaint Challenges OFAC’s Tornado Cash Sanctions

Last month, the Office of Foreign Assets Control (“OFAC”) sanctioned Tornado Cash, a virtual currency “mixer” operating on the Ethereum blockchain which allegedly has been used to launder the virtual currency equivalent of...more

SDNY Allows Putative Class Action Securities Fraud Case Based on Alleged AML Deficiencies to (Mostly) Proceed

Judge Jed Rakoff of the Southern District of New York issued an opinion last week on a motion to dismiss in a putative class action securities fraud case against Deutsche Bank (“DB”) and several current and former bank...more

New AML Whistleblower Program Highlighted by FinCEN Acting Director

Acting Director Suggests that Financial Institutions Should “Welcome” the Program - Himamauli Das, the Acting Director of the Financial Crimes Enforcement Network (“FinCEN”), spoke about the Anti-Money Laundering Act of...more

A Paradox: “De-Risking” Can Increase AML/CFT Risks By Driving People into the “Shadow Banking System”

We blogged previously on the significant steps the European Union (“EU”) recently has taken toward implementing a rigorous new transnational anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”)...more

FINRA Reminds Firms to Prepare for New AML/CFT Priorities

We previously blogged about the Financial Crimes Enforcement Network’s (“FinCEN’s”) issuance on June 30 of the first government-wide list of priorities for anti-money laundering and countering the financing of terrorism...more

European Union Round-Up:  A Summer of AML Enforcement and Compliance Proposals

European Commission Proposes EU-Level Supervisory Authority and Cryptocurrency Travel Rule - European Banking Authority Offers New Guidelines on AML Compliance Officers - Just as the United States has expanded...more

DOJ Again Uses Money Laundering Statutes to Charge Alleged Foreign Corruption Scheme — This Time in Brazil

Indictment Alleges International Scheme Involving Bribes Touching NY Correspondent Bank Accounts - The U.S. Department of Justice announced last week that U.K. law enforcement officials arrested, at its request, an...more

Review, then Reform? AMLA Charts a Path for the Future of SARs and CTRs

Eighth Blog Post in an Extended Series on Legislative Changes to the BSA/AML Regulatory Regime - As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) contains major changes to the Bank Secrecy Act (“BSA”),...more

DOJ Announces Historic Civil Forfeiture Settlement in 1MDB Case

Settlement Applies to $700 Million in Luxury Assets; Law Firms Obtain a Carve-Out - Last week, the Justice Department announced a massive settlement in the 1Malaysia Development Berhad (“1MDB”) case, a matter implicating...more

FinCEN Deputy Director Stresses Technological Innovation, Virtual Currency Enforcement and the U.S. Culture of Compliance

Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...more

Federal Reserve and FinCEN Raise Alarms Regarding Technology-Assisted Financial Fraud

The Federal Reserve and the Financial Crimes Enforcement Network, or FinCEN, both recently issued reports addressing worrisome trends in technology-assisted financial fraud.  The reports to engage the financial services...more

Congressional Funding Bill Pursues Approval of Financial Services for Marijuana Industry Through the (Temporary) Backdoor

As we have blogged, there is perplexing, significant and ongoing uncertainty regarding just how federal criminal and Bank Secrecy Act laws will be – or will not be – enforced against financial institutions providing banking...more

Standard Chartered Bank Enters Combined $1 Billion+ Settlement with U.S. and U.K. Authorities Over Iranian Financial Transactions

UK-based Standard Chartered Bank (“SCB”) announced the terms of significant settlements last week with various U.S. and U.K. governmental agencies, resolving a series of related investigations into the bank’s alleged...more

Financial Services and the Marijuana Industry: the U.S. House Mulls Regulatory Reform for Financial Institutions and...

Federal legislators continue to struggle over the growing disconnect between increasing State legalization of the cannabis industry, and the continued illegality of cannabis under federal law....more

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