On April 20, 2024, the Pennsylvania Department of Banking and Securities (“DoBS”) issued a policy statement (“Policy Statement”) to “clarify” that the Department’s interpretation of the term “money” in the Pennsylvania Money...more
5/14/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Services Business ,
Money Transmitter ,
Policy Statement ,
Virtual Currency
Incorporating in the Seychelles but Allegedly Operating in the U.S. Spells Trouble for Company and its Founders -
The Bitcoin Mercantile Exchange, or BitMEX, is a large and well-known online trading platform dealing in...more
10/13/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Bribery ,
BSA/AML ,
CFTC ,
Commodity Exchange Act (CEA) ,
Corporate Counsel ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Financial Institutions ,
Indictments ,
Know Your Customers ,
Registration Requirement ,
Suspicious Activity Reports (SARs) ,
Trading Platforms
Banks stand to advance the fight against human trafficking and modern slavery by reporting suspicious transactions and other financial activity that raise red flags, according to a report on March 15, 2017. Published by the...more
The Philippines has been identified by the U.S. as a “major money-laundering country” in the 2017 International Narcotics Control Strategy Report (“Report”), published this month. The country now joins 87 others as one “whose...more
In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more
2/7/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
Bitcoin ,
BSA/AML ,
Civil Forfeiture ,
Currency Transaction Reports (CTR) ,
Digital Currency ,
Financial Institutions ,
Forfeiture ,
Money Laundering ,
Virtual Currency
Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more
2/7/2017
/ Bitcoin ,
Department of Justice (DOJ) ,
Digital Currency ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
Internal Revenue Code (IRC) ,
IRS ,
John Doe Investigation ,
Money Laundering ,
Summons ,
Swiss Banks ,
Tax Evasion ,
Technology ,
Virtual Currency
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
2/3/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Casinos ,
Consumer Lenders ,
Customer Due Diligence (CDD) ,
FATF ,
Financial Institutions ,
FinCEN ,
Fines ,
Gambling ,
Gaming ,
Geographic Targeting Order ,
Money Laundering ,
Mortgage Lenders ,
Mortgages ,
NYDFS ,
Offshore Funds ,
Panama Papers ,
Popular ,
Real Estate Market ,
Suspicious Activity Reports (SARs) ,
Tax Evasion
A New York state law that prohibits merchants from imposing a surcharge on credit card purchases does not violate the First Amendment or the Due Process Clause, the U.S. Court of Appeals for the Second Circuit recently ruled....more
10/16/2015
/ Appeals ,
Credit Card Surcharges ,
Credit Cards ,
Debit and Credit Card Transactions ,
Due Process ,
Financial Institutions ,
First Amendment ,
Fourteenth Amendment ,
Free Speech ,
Merchants ,
Payment Systems ,
Retail Market ,
Retailers
New York City’s Responsible Banking Act (RBA) is preempted by federal and state law, a federal court has ruled. Pursuant to the New York City Charter, only financial institutions that are designated “deposit banks” by the...more
On May 6, New York Governor Andrew Cuomo announced that the New York Department of Financial Services (DFS) will soon begin examining financial institutions for their cybersecurity preparedness. Governor Cuomo stated that,...more