In an historic move this week, the Securities and Exchange Commission (SEC) and the Antitrust Division of the Department of Justice (DOJ) executed the first-ever memorandum of understanding (MOU) between the two agencies. ...more
Court Rejects Attempt by Halkbank to Enter “Special Appearance” Contesting Jurisdiction -
Turkish state-owned bank Halkbank’s efforts to avoid appearing in U.S. federal court for arraignment were squashed recently in a...more
12/24/2019
/ Arraignment ,
Bank Fraud ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Financial Institutions ,
Financial Transactions ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Personal Jurisdiction ,
Sanction Violations ,
Summons ,
White Collar Crimes ,
Willful Misconduct
A Textbook Case of Alleged Money Laundering?
On November 18, 2019, the U.S. Attorney for the Southern District of New York announced the arrest and unsealed the indictment of Bruce Bagley – a 73-year-old college professor...more
11/26/2019
/ Bribery ,
Corruption ,
Criminal Conspiracy ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Embezzlement ,
Enforcement Actions ,
Foreign Bank Accounts ,
Indictments ,
Money Laundering ,
Public Projects ,
Public Works ,
Swiss Banks ,
Venezuela ,
White Collar Crimes
Indictment Alleges that Bank and its Officers Used Front Companies to Evade Prohibitions on Iran’s Access to the U.S. Financial System -
The U.S. Attorney for the Southern District of New York has charged Turkish state-owned...more
10/28/2019
/ Bank Fraud ,
Corruption ,
Cross-Border Transactions ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Enforcement Actions ,
Financial Transactions ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Iran Sanctions ,
Money Laundering ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Sanction Violations ,
Turkey ,
United Arab Emirates (UAE) ,
White Collar Crimes
The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more
9/18/2019
/ AML/CFT ,
AMLD V ,
Anti-Corruption ,
Bank Fraud ,
Beneficial Owner ,
BSA/AML ,
Corruption ,
Criminal Conspiracy ,
Cross-Border Transactions ,
Danske Bank ,
Department of Justice (DOJ) ,
Enforcement Actions ,
EU ,
EU Directive ,
FATF ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Foreign Corrupt Practices Act (FCPA) ,
Guilty Pleas ,
Huawei ,
Individual Accountability ,
Internal Investigations ,
Money Laundering ,
Panama Papers ,
Policies and Procedures ,
Tax Evasion ,
Terrorist Financing Regulations ,
White Collar Crimes
Director Blanco Stresses Importance of BSA Filings to Criminal Investigations and Prosecutions -
As we have blogged, Kenneth Blanco, the Director of Financial Crimes Enforcement Network (“FinCEN”), has publically and...more
5/23/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Criminal Investigations ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
FinCEN ,
Information Sharing ,
Money Laundering ,
Suspicious Activity Reports (SARs)
In early March, the House Financial Services Committee released three proposed bills to codify many of the suggested reforms discussed during ongoing conversation among financial agencies, law enforcement, financial...more
3/29/2019
/ AML/CFT ,
Beneficial Owner ,
BSA/AML ,
Financial Crimes ,
Financial Regulatory Reform ,
Financial Services Committee ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Reporting Requirements ,
Shell Corporations ,
Transparency ,
White Collar Crimes
Second Post in a Two-Part Series -
In our first post in this series, we described how the U.S. Senate Committee on Banking, Housing, and Urban Affairs (the “Banking Committee”) met in open session late last week to conduct a...more
12/6/2018
/ Anti-Money Laundering ,
Artificial Intelligence ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
FBI ,
Federal Pilot Programs ,
FinCEN ,
Geographic Targeting Order ,
Legislative Agendas ,
OCC ,
Popular ,
Proposed Legislation ,
Real Estate Investments ,
Regulatory Burden
First Post in a Two-Part Series -
Late last week, the U.S. Senate Committee on Banking, Housing, and Urban Affairs (the “Banking Committee”) met in open session to conduct a hearing on “Combating Money Laundering and Other...more
12/5/2018
/ Bank Secrecy Act ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
EGRPRA ,
FBI ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Legislative Agendas ,
Money Laundering ,
OCC ,
Proposed Legislation ,
Senate Banking Committee ,
Threshold Requirements
Five U.S. regulatory agencies—the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation (“FDIC”), the National Credit Union Administration (“NCUA”), the Office of the Comptroller...more
The Financial Action Task Force (“FATF”) recently released a special report on professional money launderers (“PMLs”) who provide money laundering expertise and services to their crime-committing clients. ...more
Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses up-to-date data to identify risks to U.S. banks and measure their compliance...more
6/6/2018
/ Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Cyber Threats ,
Cybersecurity ,
Financial Fraud ,
Fraud Prevention ,
Money Laundering ,
OCC ,
Popular ,
Risk Management ,
Third-Party Risk
OCC Identifies AML/BSA and Cyber Threats as Elevated Risks Facing Banks -
Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses...more
And a Tale of Four Countries: Singapore Fines a U.K. Bank, and the U.S. Imposes a Consent Order on a Chinese Bank -
Less than a week apart, two major financial institutions (“FIs”) have been hit with penalties for failing...more
Last week, the Financial Action Task Force (“FATF”) issued a report concluding that Mexico needs to “step up efforts in pursuing money launderers.” ...more
1/9/2018
/ AML/CFT ,
Anti-Money Laundering ,
Banking Sector ,
Beneficial Owner ,
Corruption ,
FATF ,
Information Sharing ,
Know Your Customers ,
Mexico ,
Money Laundering ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
White Collar Crimes
We discuss two recent federal court opinions addressing two issues of increasing frequency and importance: (i) the potential civil liability of financial institutions to non-customers and other third-parties for alleged...more
11/20/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Financial Institutions ,
Forum Non Conveniens ,
Fraudulent Conveyance ,
Jurisdiction ,
Money Laundering ,
Popular ,
RICO ,
Suspicious Activity Reports (SARs)
This blog focuses on suggested improvements to information sharing between financial institutions, and between financial institutions and governments, to better combat money laundering and terrorist financing....more
As we recently blogged, the Royal United Services Institute (“RUSI”) for Defence and Security Studies — a U.K. think tank – has released a study: The Role of Financial Information-Sharing Partnerships in the Disruption of...more
10/23/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Information Sharing ,
Money Laundering ,
Patriot Act ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
Terrorist Financing Regulations