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Anti-Money Laundering and Sanctions: Trends and Developments Emerging Under the Trump Administration

Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more

OFAC Crystallizes Expectations for Sanctions Compliance

On March 27, 2019, the Office of Foreign Assets Control (OFAC) announced a settlement agreement with US-based Stanley Black & Decker, Inc., (Stanley Black & Decker) and its foreign subsidiary, Jiangsu Guoqiang Tools Co., Ltd....more

OFAC Identifies Digital Currency Addresses in Sanctions Designations and Provides FAQs on Digital Currency Compliance

On November 28, the Treasury Department sanctioned two Iran-based individuals for exchanging bitcoin into Iranian rials on behalf of malicious cyber actors involved in the SamSam ransomware scheme. Notably, this action marks...more

DOJ Announces New Policy on Assessing the Need for and Selection of Corporate Monitors

On October 12, 2018 in remarks made at the NYU School of Law Program on Corporate Compliance and Enforcement’s Conference on Achieving Effective Compliance, Assistant Attorney General for the U.S. Department of Justice...more

Implications of the EU General Data Privacy Regulation for US Anti-Money Laundering and Economic Sanctions Compliance

Many financial institutions will confront a new compliance challenge on May 25, 2018, the effective date of the European Union’s revamped data privacy law, the General Data Protection Regulation (“GDPR”). In short, GDPR data...more

FinCEN Releases Frequently Asked Questions Regarding Customer Due Diligence and Beneficial Ownership Requirements

Last week the Financial Crimes Enforcement Network (FinCEN) issued much-anticipated Frequently Asked Questions (FAQs) that provide additional guidance to financial institutions relating to the implementation of the new...more

FinCEN Launches New Information-Sharing Platform: The FinCEN Exchange

Treasury's Financial Crimes Enforcement Network (“FinCEN”) recently announced the creation of the FinCEN Exchange, a new voluntary platform to facilitate information sharing between the government and industry on topics...more

Ninth Circuit Applies the Holocaust Expropriated Art Recovery Act of 2016 to Revive Previously Dismissed Nazi-Era Art...

On July 10, 2017, the US Court of Appeals for the Ninth Circuit became the first circuit court to apply the six-year statute of limitations from the Holocaust Expropriated Art Recovery Act of 2016 (HEAR Act). In Cassirer v....more

Hobby Lobby Forfeits Thousands of Ancient Iraqi Artifacts, Pays $3M, and Admits Fault to Settle Civil Forfeiture Action

The US government's settlement with Hobby Lobby on July 5, 2017 is part of its broader effort to combat trafficking in looted antiquities from the war-torn Middle East and to reduce market demand for such objects by punishing...more

Supreme Court Substantially Reduces Government's Ability to Seek Criminal Forfeitures

On June 5, 2017, the Supreme Court issued a unanimous opinion in Honeycutt v. United States (No. 16-142), holding that a criminal defendant can be held liable to forfeit only crime proceeds the defendant personally obtained,...more

AML and Sanctions: 2017 Trends and Developments

Over the past year, regulators continued to actively examine compliance, introduce new and heightened requirements, recalibrate global priorities, and aggressively pursue enforcement. This report reviews recent trends and...more

Scope Of The Jury Trial Right In Civil FIRREA Actions

In recent years, the U.S. Department of Justice has stepped up its use of the Financial Institutions Reform, Recovery and Enforcement Act of 1989 to pursue civil enforcement actions against financial institutions and their...more

NYDFS Issues Final Rule Requiring Certification of Compliance With AML Transaction Monitoring and Filtering Program Requirements

The New York Department of Financial Services (NYDFS) recently finalized a regulation that mandates detailed elements of the anti-money laundering (AML) transaction monitoring and sanctions filtering programs of covered...more

Anti–Money Laundering Alert: FinCEN Finalizes Beneficial Ownership and Customer Due Diligence Requirements

The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more

Federal Regulators Clarify Bank CIP Obligations for Prepaid Cardholders

Banks and credit unions that issue reloadable, general purpose prepaid cards must apply Customer Identification Program (CIP) procedures to those cardholders, according to guidance issued by the federal banking regulators and...more

FinCEN Sets Its Sights on Luxury Real Estate

Overview - On January 13, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued Geographic Targeting Orders (GTOs) that will temporarily require title insurance companies to report...more

AML Litigation and Individual Liability: FinCEN's Landmark Haider Case Moves Forward

A federal district court in Minnesota recently held that the Bank Secrecy Act (BSA) permits the Financial Crimes Enforcement Network (FinCEN) to bring suit against individuals for willfully violating the BSA's AML program...more

Iran Nuclear Sanctions Relief Implemented: New Opportunities Await Non-US Companies, but Comprehensive US Transaction and Export...

On January 16, 2016, the United States, its negotiating partners and Iran announced the arrival of Implementation Day for the Joint Comprehensive Plan of Action (JCPOA), to which the parties agreed on July 14, 2015 with...more

NYDFS Proposes to Require Chief Compliance Officers to Certify Effectiveness of AML and Sanctions Programs

The New York Department of Financial Services has issued a proposed regulation that sets forth minimum requirements for anti-money laundering transaction monitoring systems and watch list filtering systems. The proposed...more

FinCEN Proposes AML Requirements for Registered Investment Advisers

The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA). The August 25, 2015...more

Final Deal Reached on Iran Sanctions Relief

On July 14, 2015, the United States and its P5+1 negotiating partners, together with Iran, announced the final terms of the Joint Comprehensive Plan of Action (JCPOA) concerning Iran’s nuclear program. The JCPOA is designed...more

Treasury Department Issues Comprehensive Assessment of US Money Laundering and Terrorist Financing Risk

For the first time in a decade, the Treasury Department has released its own anti–money laundering (AML) and terrorist financing Risk Assessments, which may both set a strategic framework for future AML regulatory...more

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