On August 27, 2024, the New York State Department of Financial Services (“NYDFS”) announced a consent order involving a $35 million settlement with Nordea Bank Abp (“Nordea”) for alleged significant failures related to...more
9/5/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Consent Order ,
Due Diligence ,
Financial Institutions ,
Financial Services Industry ,
Money Laundering ,
NYDFS ,
Panama Papers
On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more
5/8/2024
/ AML/CFT ,
Anti-Money Laundering ,
Banks ,
BSA/AML ,
Due Diligence ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
OCC ,
Risk Assessment ,
Risk Management ,
Third-Party ,
Third-Party Risk
The Financial Crimes Enforcement Network (“FinCEN”) recently released a Financial Trend Analysis (“FTA”) focusing on identity-related suspicious activity. The FTA was issued pursuant to section 6206 of the Anti-Money...more
Summary -
The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more
12/6/2023
/ Anti-Bribery ,
Anti-Corruption ,
Anti-Money Laundering ,
Bribery ,
Corporate Crimes ,
Corruption ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
FCPA Corporate Enforcement Policy (CEP) ,
Financial Crimes ,
Foreign Corrupt Practices Act (FCPA) ,
Fraud ,
Money Laundering ,
White Collar Crimes
On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more
11/1/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Convertible Virtual Currencies (CVCs) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
NPRM ,
Recordkeeping Requirements ,
Virtual Currency
The U.S. Department of Justice (“DOJ”) announced on March 15, 2023 that in a coordinated effort between U.S. Federal Bureau of Investigations, Europol, and German police, the darknet cryptocurrency mixing service ChipMixer...more
On January 4, 2023, the New York State Department of Financial Services (“NYDFS”) issued a consent order against Coinbase, Inc. (“Coinbase” or the “Company”), the largest U.S.-based cryptocurrency trading exchange, for...more
First Post in a Two-Post Series on the CTA Implementing Regulations -
On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued its final rule, Beneficial Ownership Information Reporting...more
Case Highlights the Role of Correspondent Bank Accounts and Circumvention of AML Programs -
Court Order Describes Seizure as a “Reckoning” for Atrocities in the Ukraine...more
On January 13, 2022, Himamauli “Him” Das, the Acting Director of FinCEN, virtually addressed the Financial Crimes Enforcement Conference hosted by the American Bankers Association and the American Bar Association. In his...more
Government Alleges Systemic and Deliberate AML Failures -
Filings Describe Tools for CVC Exchanges to Use for Customer Due Diligence and Transaction Monitoring -
The Financial Crimes Enforcement Network (“FinCEN”) and...more
Seventh Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
On April 5, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued an advance notice of proposed rulemaking (“ANPRM”) to...more
On February 25, 2021, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to the Bank Secretary Act/Anti-Money Laundering (“BSA/AML”) Examination Manual (the “Manual”), which provides guidance to...more