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Conducting Effective Sanctions and Anti-Money Laundering Diligence on Non-Latin-Based Entities

With the ever-increasing use of sanctions as a foreign policy tool (or weapon), sanctions compliance has taken on greater importance than ever. Moreover, as countries increase extraterritorial applications of their sanctions,...more

FinCEN Proposes New Rule on Beneficial Ownership Information Access and Safeguards for Corporate Transparency Act

The US Treasury’s Financial Crimes Enforcement Network (FinCEN) recently proposed a new rule (the Proposed Rule) regarding beneficial ownership information access and safeguards pursuant to the Corporate Transparency Act....more

FinCEN Proposes Crypto Reporting and Recordkeeping Requirements

Recently proposed regulations could present significant compliance burdens for the banks and money service businesses that engage in cryptocurrency transactions with unhosted wallets or wallets held in jurisdictions specified...more

Agencies Emphasize Risk-Based Due Diligence Approach for Charities and Nonprofits

The Agencies issued a joint Fact Sheet that lists considerations for a risk-based approach when it comes to charities and nonprofits. While the Fact Sheet purports to not impose additional obligations on banks, it is hard to...more

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