On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its assessment of a civil monetary penalty totaling $450,000 against Michael LaFontaine, a former Chief Operational...more
For the past several years, advocates of crypto assets and other public uses of blockchain technology have sought guidance from U.S. regulators regarding the legal implications of new or novel uses of that technology....more
5/21/2019
/ Anonymization ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Blockchain ,
BSA/AML ,
CFTC ,
Cryptocurrency ,
Digital Wallets ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Money Services Business ,
New Guidance ,
Peer-to-Peer ,
Securities and Exchange Commission (SEC) ,
Virtual Currency
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program -
On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
5/6/2019
/ Audits ,
Bank Secrecy Act ,
Compliance ,
Economic Sanctions ,
Employee Training ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Risk Assessment ,
Sanction Violations ,
U.S. Treasury
On May 11, 2018, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) implemented its Final Rule on Customer Due Diligence Requirements for Financial Institutions (“Rule”) to amend the scope of...more
Superintendent of New York State Department of Financial Services (“NYDFS”), Maria T. Vullo, has focused the Department’s efforts on enforcement of New York’s Anti-Money Laundering (“AML”) laws. Since her confirmation on June...more
On October 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published an Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime and an accompanying Frequently Asked...more