Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more
11/30/2016
/ Anti-Money Laundering ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
Due Diligence ,
EU ,
FATF ,
Financial Institutions ,
FinCEN ,
Member State ,
Office of Foreign Assets Control (OFAC) ,
Terrorism Funding ,
Virtual Currency
On October 25, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory (the “Advisory”) explaining the obligations a “financial institution” might have under the Bank Secrecy Act (“BSA”) regarding...more
Under Securities and Exchange Commission (“SEC”) authorization, the Financial Industry Regulatory Authority (“FINRA”) is “responsible for regulating (1) all securities firms that do business with the public[,]” (2) key stock...more
4/25/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Broker-Dealer ,
Compliance ,
Corporate Culture ,
Enforcement Actions ,
Examination Priorities ,
Financial Industry Regulatory Authority (FINRA) ,
FinCEN ,
Risk Management ,
Securities and Exchange Commission (SEC)
In an unprecedented event earlier this week, 11.5 million files from the Panamanian law firm Mossack Fonseca were allegedly leaked. Assuming they are genuine, as appears to be the case, these “Panama Papers” offer a...more
4/12/2016
/ Anti-Corruption ,
Bribery ,
BSA/AML ,
Criminal Penalties ,
Department of Justice (DOJ) ,
Due Diligence ,
Enforcement Actions ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Panama Papers ,
Risk Mitigation ,
Securities and Exchange Commission (SEC) ,
Shell Corporations ,
Young Lawyers
This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more
11/2/2015
/ Advertising ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Compliance ,
Department of Justice (DOJ) ,
Fantasy Sports ,
Financial Institutions ,
FinCEN ,
Football ,
Gambling ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Online Gaming ,
Online Platforms ,
SAR ,
Sports ,
Sports Gambling ,
Suspicious Activity Reports (SARs) ,
Unlawful Internet Gambling Enforcement Act (UIGEA) ,
Venture Capital