Governments worldwide are sharpening their focus on money laundering executed through international trade. Anti-money laundering obligations on entities beyond traditional financial institutions continue to expand. Companies...more
The override of former President Trump's veto of the National Defense Authorization Act of 2021 resulted in the enactment of broad amendments to the US anti-money laundering regime. Among the amendments are provisions to...more
The override of former President Trump's veto of the National Defense Authorization Act of 2021 resulted in the enactment of broad amendments to the US anti-money laundering regime. Of particular note is the inclusion of the...more
1/28/2021
/ Anti-Money Laundering ,
Beneficial Owner ,
Closely Held Businesses ,
Corporate Transparency Act ,
Covered Entities ,
Customer Due Diligence (CDD) ,
FinCEN ,
Limited Liability Company (LLC) ,
NDAA ,
Shell Corporations ,
Special Purpose Vehicles
A controversial proposed rule from the Financial Crimes Enforcement Network would bring bank-like regulation of virtual asset transactions, including the first broadly-applied AML reporting requirement in at least two...more
1/7/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Cryptocurrency ,
Currency Transaction Reports (CTR) ,
Digital Assets ,
FinCEN ,
Money Services Business ,
NPRM ,
Patriot Act ,
Proposed Regulation ,
Proposed Rules ,
Recordkeeping Requirements ,
Virtual Currency
The Financial Action Task Force ("FATF"), the international standard-setting body for national anti-financial crimes regimes, recently issued new obligations for governments and, by extension, financial institutions ("FI"),...more
On September 16, the US Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) seeking to update the US anti-money laundering (AML) regime. This is an historic opportunity for...more
11/5/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Proposed Amendments ,
Public Comment ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more
9/24/2020
/ Bank Fraud ,
BSA/AML ,
Corruption ,
Customer Due Diligence (CDD) ,
FATF ,
Federal Bank Regulatory Agencies ,
Financial Institutions ,
FinCEN ,
Joint Statements ,
Money Laundering ,
National Security ,
Politically Exposed Person (PEPs) ,
Risk Assessment ,
Senior Foreign Political Figures (SFPFs)
On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) issued guidance explaining how financial institutions can conduct due diligence for hemp-related businesses and identifying the type of information and...more
8/15/2020
/ Anti-Money Laundering ,
Banking Sector ,
Controlled Substances Act ,
Due Diligence ,
Farm Bill ,
Financial Institutions ,
FinCEN ,
Hemp ,
Hemp Related Businesses ,
New Guidance ,
Required Documentation ,
Suspicious Activity Reports (SARs) ,
USDA
On December 3, 2019, in a rare public statement regarding the provision of banking services to cannabis- or hemp-related businesses, the Federal Banking Agencies, including the Board of Governors of the Federal Reserve...more
12/11/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Controlled Substances Act ,
Farm Bill ,
Federal Bank Regulatory Agencies ,
Financial Services Industry ,
FinCEN ,
Hemp ,
Hemp Related Businesses ,
Interagency Guidance ,
Joint Statements ,
NCUA ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
USDA
On September 25, 2019, the US House of Representatives ("House") passed, by a vote of 321 to 103, the Secure and Fair Enforcement Banking Act ("SAFE Banking Act"), bipartisan legislation designed to secure and regulate...more
10/9/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Canada ,
Cannabis Products ,
Cannabis-Related Businesses (CRBs) ,
Cole Memorandum ,
Controlled Substances Act ,
Cross-Border Transactions ,
Department of Justice (DOJ) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Harmonization Rules ,
Hemp ,
Marijuana Related Businesses ,
Medical Marijuana ,
NYDFS ,
Popular ,
Proposed Legislation ,
Rohrabacher-Farr Amendment ,
Suspicious Activity Reports (SARs) ,
USDA
In recent months, support for Bank Secrecy Act/anti-money laundering ("BSA/AML") reform has gained momentum in the US Congress as more than 20 pieces of reform-related legislation circulate the financial services committees....more
9/12/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Criminal Prosecution ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Money Laundering ,
Money Laundering Control Act (MLCA) of 1986 ,
Suspicious Activity Reports (SARs)
Canada legalised recreational cannabis in October 2018 and it may be that other countries follow suit. UK and US investors, and those who facilitate investments in legal recreational cannabis businesses overseas, need to be...more
3/25/2019
/ Anti-Money Laundering ,
Canada ,
Criminal Liability ,
Criminal Proceeds ,
Cross-Border Transactions ,
Decriminalization of Marijuana ,
Financial Institutions ,
Foreign Investment ,
Investor Protection ,
Marijuana Related Businesses ,
National Crime Agency (NCA) ,
Proceeds of Crime Act 2002 (POCA) ,
Suspicious Activity Reports (SARs) ,
UK
Financial firms play an integral role in preventing, identifying, investigating and reporting criminal activity, including terrorist financing, money laundering, and many other finance-related crimes. It is a critical role...more
2/2/2019
/ Anti-Money Laundering ,
Artificial Intelligence ,
Bank Secrecy Act ,
Banking Sector ,
Confidentiality Policies ,
Distributed Ledger Technology (DLT) ,
EU ,
Financial Institutions ,
FinCEN ,
General Data Protection Regulation (GDPR) ,
Information Sharing ,
Innovative Technology ,
Money Laundering ,
Patriot Act ,
Privacy Laws ,
Suspicious Activity Reports (SARs) ,
Technology Sector ,
Terrorist Financing
TABLE OF CONTENTS:
Executive Summary -
Developments and Trends in Policy and Enforcement
- US Department of the Treasury
- The Office of Foreign Assets Control
- Treasury's Financial Crimes Enforcement Network
-...more
1/22/2019
/ Anti-Money Laundering ,
Banks ,
Broker-Dealer ,
BSA/AML ,
CFTC ,
Civil Monetary Penalty ,
Compliance ,
Cuba ,
Customer Due Diligence (CDD) ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Digital Currency ,
Economic Sanctions ,
Enforcement Actions ,
FDIC ,
FFIEC ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
FinCEN ,
FinTech ,
FRB ,
Guilty Pleas ,
Information Sharing ,
Investment Banks ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Nicaragua ,
North Korea ,
NYDFS ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Piling-On ,
Russia ,
Sanction Violations ,
Securities and Exchange Commission (SEC) ,
Settlement ,
Sudan ,
Suspicious Activity Reports (SARs) ,
Syria ,
Terrorism Funding ,
U.S. Treasury ,
Ukraine ,
Venezuela