On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more
On September 29, 2022, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a long-awaited final rule implementing the beneficial ownership information (BOI) reporting requirements of the...more
On September 16, 2022, the U.S. Department of the Treasury and Department of Justice released four much-anticipated reports on different aspects of cryptoasset regulation. They confirm the Biden administration’s broad but...more
9/29/2022
/ Biden Administration ,
Blockchain ,
Criminal Investigations ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Financial Regulatory Agencies ,
Non-Fungible Tokens (NFTs) ,
Popular ,
U.S. Treasury
On December 7, 2021, the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting...more
On October 15, 2021, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued detailed guidance to the virtual currency industry, putting virtual currency companies on notice of the ways OFAC...more
On June 30, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first government-wide priorities (Priorities) for combatting money laundering and the financing of terrorism.1...more
7/22/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Financial Institutions ,
FinCEN ,
Human Trafficking ,
Internal Controls ,
National Security ,
Terrorist Financing ,
Terrorist Financing Regulations
Sanctions -
The Biden administration has made clear that economic sanctions will continue to be an important U.S. foreign policy tool and has initiated a comprehensive review of current sanctions policies and practices....more
On April 1, 2021, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) to solicit public comments on the implementation of the Corporate...more
This issue discusses a variety of legal, regulatory and enforcement developments in the digital asset space in the U.S. and Europe....more
4/19/2021
/ Bitcoin ,
Blockchain ,
CFTC ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Distributed Ledger Technology (DLT) ,
Enforcement Actions ,
Ethereum ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Investment Adviser ,
Non-Fungible Tokens (NFTs) ,
Securities and Exchange Commission (SEC) ,
Smart Contracts ,
Virtual Currency
On January 7, 2021, the original 15-day comment period ended for a proposed rule announced by the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) that would impose new reporting, recordkeeping...more
On January 1, 2021, the United States Congress overrode the president’s veto to enact the 2021 National Defense Authorization Act (the NDAA), which, aside from allocating the annual defense budget, includes the Anti-Money...more
On October 27, 2020, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the Federal Reserve System (Federal Reserve, together with FinCEN, “the Agencies”)...more
11/11/2020
/ Bank Secrecy Act ,
FATF ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Fund Transfers ,
Know Your Customers ,
Money Services Business ,
Money Transmitter ,
National Security ,
Notice of Proposed Rulemaking (NOPR) ,
Public Comment ,
Recordkeeping Requirements ,
Travel Rule ,
Virtual Currency
On November 5, 2018, the United States reimposed all remaining nuclear-related sanctions against Iran that it had previously lifted in connection with its implementation of the Joint Comprehensive Plan of Action (JCPOA) in...more
11/13/2018
/ Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Iran ,
Iran Sanctions ,
ITSR ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nuclear Power ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
SDN List ,
Secondary Sanctions ,
Trump Administration ,
Winding Down ,
Withdrawal
On November 1, 2018, President Donald Trump issued Executive Order 13850 (E.O. 13850), which broadly targets corrupt practices in Venezuela and builds on several recent rounds of U.S. sanctions against the Venezuelan...more
11/9/2018
/ Corruption ,
Defense Sector ,
Economic Sanctions ,
Energy Sector ,
Engineering ,
Executive Orders ,
Government Officials ,
Mining ,
Rare Earth Metals ,
State-Owned Enterprises ,
Trump Administration ,
Venezuela
Effective May 11, 2018, covered financial institutions are required to comply with the customer due diligence rule (the Rule) that the Financial Crimes Enforcement Network (FinCEN) finalized in May 2016. The Rule mandates the...more
5/16/2018
/ Banks ,
Beneficial Owner ,
Compliance ,
Covered Financial Institutions ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Financial Institutions ,
FinCEN ,
Legal Entities ,
Loans ,
Suspicious Activity Reports (SARs) ,
Trusts ,
Verification Requirements
In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more
5/17/2016
/ Anti-Money Laundering ,
Banks ,
Customer Due Diligence (CDD) ,
Due Diligence ,
Economic Sanctions ,
EU ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Ownership Requirements ,
Popular ,
Transparency ,
White Collar Crimes