On November 1, 2021, the President’s Working Group on Financial Markets (PWG) - along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) - published the Report on...more
11/16/2021
/ Anti-Money Laundering ,
Blockchain ,
CFTC ,
Cross-Border ,
Cryptocurrency ,
Exchange Rates ,
FDIC ,
FinCEN ,
FSOC ,
Information Reports ,
Legislative Agendas ,
OCC ,
Payment Systems ,
Prudential Regulation Authority (PRA) ,
Regulatory Agenda ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Stablecoins
The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more
7/15/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Biden Administration ,
Compliance ,
Cybersecurity ,
Drug Trafficking ,
Enforcement Priorities ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Human Trafficking ,
No-Action Letters ,
Nonbank Firms ,
Ransomware ,
Significant Transnational Criminal Organization ,
Terrorism Funding ,
Virtual Currency
Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more
2/12/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
NDAA ,
Patriot Act ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
Two recent actions by the Office of the Comptroller of the Currency (OCC) - one enforcement action and one interpretive note - focus attention on the kinds of anti–money laundering (AML) controls needed for banks to custody...more
8/7/2020
/ Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Consent Order ,
Cryptoassets ,
Cryptocurrency ,
Custody ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
OCC
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
7/29/2019
/ Anti-Money Laundering ,
BSA/AML ,
Cuba ,
Customer Due Diligence (CDD) ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Human Trafficking ,
Iran ,
Magnitsky Act ,
Nicaragua ,
North Korea ,
Russia ,
Sudan ,
Trump Administration ,
Venezuela ,
Virtual Currency
The myriad—and conflicting—state, federal and international laws governing the burgeoning marijuana industry have created a complicated legal landscape for financial institutions. In the United States, most states have...more
2/8/2019
/ Anti-Money Laundering ,
Canada ,
Cannabidiol (CBD) oil ,
Cole Memorandum ,
Controlled Substances Act ,
Decriminalization of Marijuana ,
Farm Bill ,
Financial Institutions ,
FinCEN ,
Food and Drug Administration (FDA) ,
Hemp ,
Marijuana ,
Marijuana Related Businesses ,
Proceeds of Crime Act 2002 (POCA) ,
Regulatory Agenda ,
Risk Management ,
State and Local Government ,
Suspicious Activity Reports (SARs)
Many financial institutions will confront a new compliance challenge on May 25, 2018, the effective date of the European Union’s revamped data privacy law, the General Data Protection Regulation (“GDPR”). In short, GDPR data...more
Last week the Financial Crimes Enforcement Network (FinCEN) issued much-anticipated Frequently Asked Questions (FAQs) that provide additional guidance to financial institutions relating to the implementation of the new...more
Treasury's Financial Crimes Enforcement Network (“FinCEN”) recently announced the creation of the FinCEN Exchange, a new voluntary platform to facilitate information sharing between the government and industry on topics...more
The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more
6/2/2016
/ Anti-Money Laundering ,
Beneficial Owner ,
Covered Financial Institutions ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
FATF ,
Final Rules ,
FinCEN ,
Legal Entities ,
Panama Papers ,
Risk-Based Approaches ,
Suspicious Activity Reports (SARs)
Banks and credit unions that issue reloadable, general purpose prepaid cards must apply Customer Identification Program (CIP) procedures to those cardholders, according to guidance issued by the federal banking regulators and...more
For the first time in a decade, the Treasury Department has released its own anti–money laundering (AML) and terrorist financing Risk Assessments, which may both set a strategic framework for future AML regulatory...more
6/19/2015
/ AML/CFT ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Banking Sector ,
Casinos ,
Corporate Counsel ,
Digital Currency ,
FATF ,
Financial Institutions ,
Prepaid Payment Products ,
Risk Assessment ,
Securities ,
U.S. Treasury