As cryptocurrency’s market cap surpasses the $2.5 trillion mark and continues to climb, global regulators have turned their attention to understanding and addressing the risks surrounding digital assets.
In recent years,...more
7/16/2021
/ Anti-Money Laundering ,
Cryptocurrency ,
Customer Identification Program (CIP) ,
Department of Justice (DOJ) ,
Digital Assets ,
Financial Conduct Authority (FCA) ,
FinCEN ,
Know Your Customers ,
NDAA ,
Popular ,
Risk Assessment ,
Terrorism Funding
Modernizing FinCEN’s Whistleblower Program Under the Anti-Money Laundering Act of 2020 -
INTRODUCTION -
Reporting on multiple international money-laundering schemes last year brought public focus to the anti-money...more
5/21/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CFTC ,
Department of Justice (DOJ) ,
Dodd-Frank ,
False Claims Act (FCA) ,
FinCEN ,
IRS ,
NDAA ,
Sarbanes-Oxley ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
The Financial Institutions Reform, Recovery and Enforcement Act of 1989 (“FIRREA”) is a powerful tool in the prosecutorial arsenal. Due to its long statute of limitations, expansive penalty provision, and low civil burden of...more
3/19/2021
/ CARES Act ,
Civil Monetary Penalty ,
CMBS ,
Coronavirus/COVID-19 ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Financial Institutions ,
FIRREA ,
Fraud ,
Paycheck Protection Program (PPP) ,
SBA ,
U.S. Treasury
As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more
12/23/2020
/ Anti-Money Laundering ,
Civil Monetary Penalty ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Limited Liability Company (LLC) ,
NDAA ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Securities Exchange Act ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury ,
Whistleblowers
Every change in presidential administration results in shifts to agencies’ policy priorities and enforcement efforts. In a Biden Administration, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”), in particular,...more
12/18/2020
/ Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
Disparate Impact ,
ECOA ,
Enforcement Actions ,
Fair Housing Act (FHA) ,
HUD ,
Protected Class ,
Racial Bias
In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more
11/5/2020
/ Bank Secrecy Act ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FATF ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Proposed Rules ,
Suspicious Activity Reports (SARs) ,
Travel Rule ,
Uniform Commercial Code (UCC) ,
Virtual Currency ,
Wire Transfers
In the past, sanctioned jurisdictions like Venezuela have embraced virtual currency as a way to bypass channels that involve U.S. dollars, blunting the impact of U.S. economic sanctions policies aimed at isolating those...more
3/12/2020
/ Anti-Money Laundering ,
Bitcoin ,
Blockchain ,
Cryptocurrency ,
Cyber Crimes ,
Cybersecurity ,
Department of Justice (DOJ) ,
International Emergency Economic Powers Act (IEEPA) ,
Iran ,
Law Enforcement ,
National Security ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
U.S. Treasury ,
Virtual Currency