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
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
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
10/20/2023
/ Alternative Trading System (ATS) ,
AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Due Diligence ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
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
8/17/2023
/ Bitcoin ,
Blockchain ,
Criminal Conspiracy ,
Criminal Prosecution ,
Crypto Exchanges ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Financial Crimes ,
Financial Fraud ,
Guilty Pleas ,
Money Laundering ,
Plea Agreements
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
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
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
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
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
11/6/2019
/ 1MDB ,
Bribery ,
Campaign Contributions ,
Cayman Islands ,
Civil Forfeiture ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
EMI Entertainment ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Forfeiture ,
Malaysia ,
Money Laundering ,
Regulatory Violations ,
Settlement Agreements ,
Sovereign Wealth Funds ,
White Collar Crimes
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
8/2/2019
/ Business E-Mail Compromise (BEC) ,
Federal Reserve ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Identity Theft ,
Innovative Technology ,
Know Your Customers ,
Money Laundering ,
Personally Identifiable Information ,
Suspicious Activity Reports (SARs) ,
Vulnerability Assessments
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
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
4/17/2019
/ Anti-Money Laundering ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Financial Conduct Authority (FCA) ,
Fines ,
Forfeiture ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Settlement Agreements ,
Standard Chartered Bank
The U.S. Department of Justice (“DOJ”) continues to pursue Venezuelan nationals through high-dollar and high-profile money laundering and foreign bribery charges....more
12/10/2018
/ Bribery ,
Corruption ,
Criminal Prosecution ,
Currency Exchange ,
Currency Manipulation ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Venezuela ,
White Collar Crimes