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FATF Updates Risk-Based Approach Guidance for the Real Estate Sector

As we have repeatedly blogged, concerns about perceived anti-money laundering (“AML”) risks in the real estate industry are rising globally. Consistent with this concern, the Financial Action Task Force (“FATF”) has updated...more

BitMEX Co-Founder and Owner Settles with CFTC and Now Faces Criminal Sentencing

The legal saga involving the civil and criminal cases against the entity and former individual owners of the Bitcoin Mercantile Exchange, or BitMEX—a large and well-known online trading platform dealing in futures contracts...more

American Bankers Association and the Bank Policy Institute Weigh in on FinCEN’s Proposed Rules for Corporate Transparency Act

As we recently blogged (here and here), the Financial Crimes Enforcement Network (“FinCEN”) recently issued a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership reporting requirements of the Corporate...more

U.S. Sentencing Commission Data on Money Laundering and BSA-Related Offenses Reveals:  Courts Often Sentence Below the Guidelines...

Sentencing is a critical stage in the federal criminal process, particularly given the incredibly high rate of guilty pleas in federal court. There is a very strong argument that sentencing far eclipses the importance of the...more

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