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
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
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