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Comparison of Short-Term Cash Management Alternatives

In response to recent client questions regarding the various considerations and options for holding short-term funds, we have prepared a reference chart comparing certain key characteristics of demand deposits with government...more

Distressed Bank Update as of March 16, 2023

In the three days since federal authorities announced sweeping measures to protect depositors of Silicon Valley Bank (SVB) and Signature Bank and help prevent additional bank failures (as discussed in our update of March 12,...more

Distressed Bank Update as of March 12, 2023

At 6:15 p.m. ET on March 12, 2023, the Department of the Treasury, Federal Reserve, and FDIC announced “actions enabling the FDIC to complete its resolution of Silicon Valley Bank, Santa Clara, California, in a manner that...more

Silicon Valley Bank Update as of March 11, 2023

Below is an overview of the failure of Silicon Valley Bank (SVB) and what we expect to happen next. This reflects information as of 4:00 p.m. PT on March 11, 2023. We note that it is an evolving situation; we will provide...more

DOJ Announces Shift Toward Corporate Enforcement for Sanctions and Export Control Violations

Deputy Attorney General (DAG) Lisa Monaco once again delivered groundbreaking remarks at the American Bar Association (ABA) National Institute on White Collar Crime (ABA White Collar Conference) on March 2, 2023, this time...more

FinCEN Issues Proposed Rule for Accessing Ownership Information Under the Corporate Transparency Act

The U.S. Department of the Treasury’s (the Treasury) Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated final rule on September 29, 2022, implementing the beneficial ownership information (BOI)...more

US Outlines Increased Sanctions on Foreign Parties Continuing To Transact With Russia Sanctions Targets

The U.S. government issued guidance on October 14, 2022, emphasizing that the United States is “prepared to use its broad targeting authorities against non-U.S. persons” who continue to trade with Russia sanctions targets,...more

FinCEN’s Highly Anticipated Beneficial Ownership Reporting Rule Under CTA Effective January 1, 2024

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its highly anticipated final rule implementing the beneficial ownership information (BOI) reporting requirements of the Corporate...more

Federal Reserve Issues Final Guidelines for Master Account Access

The Board of Governors of the Federal Reserve System (the Board), on August 15, 2022, issued final guidelines for regional Federal Reserve Banks to use when considering applications for Federal Reserve “master...more

OFAC Takes Action Against Virtual Currency Tornado Cash in Novel Application of Sanctions Authorities

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), on August 8, 2022, sanctioned virtual currency mixer Tornado Cash. OFAC alleged that it had been “used to launder more than $7 billion worth of...more

US Treasury Highlights Anti-Money Laundering Priorities in 2022 Illicit Finance Strategy

The U.S. Department of the Treasury (Treasury), on May 13, 2022, published its 2022 National Illicit Finance Strategy (the 2022 Strategy)—a comprehensive statement of the agency’s key priorities, goals, and plans for...more

Sanctions Are the New FCPA: US Pledges Enforcement, Issues New Russia Sanctions and Export Controls

As Russia’s invasion of Ukraine persists, with no end currently in sight, the United States continues to issue increasingly punishing economic sanctions and export controls targeting Russia, most recently aiming at the...more

War in Ukraine Prompts Further Trade Sanctions by the United States

Russia’s invasion into Ukraine in February 2022 has prompted the United States and its allies, including the United Kingdom, the European Union, and others, to issue substantial international trade restrictions such as...more

Recent Developments in US Sanctions and Export Controls Targeting Russia

Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more

Sanctioning Russia Over Invasion of Ukraine

On February 21, 2022, Russian President Vladimir Putin unilaterally recognized the Luhansk and Donetsk regions in Eastern Ukraine (Covered Regions) as independent states. Thereafter, Mr. Putin authorized a full-scale invasion...more

FinCEN Solicits Comments on Striking Expansion of Anti-Money Laundering Obligations to Real Estate Sector

The Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (ANPRM) on December 6, 2021, soliciting comments on the potential extension of the Bank Secrecy Act (BSA), and the attendant...more

FinCEN Proposed Beneficial Ownership Rule

On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated proposed rule that would implement key provisions of the Corporate Transparency Act (CTA), a...more

Consumer Financial Protection Bureau Issues 25th Supervisory Highlights

On December 8th, the Consumer Financial Protection Bureau (CFPB) issued the 25th edition of its Supervisory Highlights report, which covers examinations completed in the first half of 2021. The CFPB reported on violations...more

The Anti-Money Laundering Act of 2020: The Remarkable Expansion of the U.S. Government’s Subpoena Power Over Foreign Financial...

On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering, terrorism...more

OFAC Releases New Detailed Guidance for the Digital Currency Industry

On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released guidance on sanctions compliance for the digital currency industry, the agency’s most detailed guidance to date on...more

OFAC Issues Second Ransomware Advisory and Designates Virtual Currency Exchange for Sanctions

Agency’s Focus on Cryptocurrency and Blockchain Continues - On September 21, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) released an updated advisory to “highlight the sanctions...more

AMLA 2020 Series Part 3: FinCEN Issues Notice of Proposed AML Rules for Antiquities Dealers

On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more

AMLA 2020 Series Part 2: New Bank Secrecy Act Whistleblower Provisions

On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more

FINRA, Federal Banking Agencies Issue Guidance on Third-Party Risk Management

Recent guidance from financial industry regulators reminds market participants to remain mindful of their business, compliance, and operational obligations when incorporating technology vendors as a fundamental part of their...more

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