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United States V. Danske Bank: New Theory of Liability for Violation of US AML Standards

This Article discusses the recent plea agreement between the United States and Danske Bank. It argues that the Department of Justice has advanced a new and evolving theory of liability for foreign banks that access the U.S....more

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Biden to Federal Government: Assess Financial Risk of Climate Change

On May 20, President Biden issued his Executive Order on Climate-Related Financial Risk (“Order”) which requires federal agencies to assess the potential impacts of climate change on public and private financial institutions...more

New York Legalizes Marijuana - Where Is the US Headed?

It’s been an eventful week for the marijuana industry. After years of false starts, New York legalized the use of recreational marijuana on March 31 - just hours later, New Mexico legislators passed a bill to do the same....more

2021 AML Trends and Developments

Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more

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