On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its assessment of a civil monetary penalty totaling $450,000 against Michael LaFontaine, a former Chief Operational...more
The Financial Action Task Force (“FATF”) held its 31st plenary meeting during February 19-21, 2020. Among other things, the FATF classified Iran as a “high-risk jurisdiction” and called for certain countermeasures to be...more
3/4/2020
/ AML/CFT ,
Blocking Statutes ,
EU ,
FATF ,
Financial Action Task Force ,
FinCEN ,
High-Risk Countries ,
Iran ,
Money Laundering ,
New Regulations ,
Terrorist Financing Regulations
The Travel Rule is an old friend for those familiar with banking regulations and anti-money laundering rules. The Rule, first issued by FinCEN in 1995 with fiat currency in mind, requires banks and nonbank financial...more
10/2/2019
/ Anti-Money Laundering ,
Bitcoin ,
Cryptocurrency ,
Data Security ,
FATF ,
FinCEN ,
Money Services Business ,
New Guidance ,
Public Comment ,
Regulatory Requirements ,
Travel Rule ,
Virtual Currency
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program -
On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
5/6/2019
/ Audits ,
Bank Secrecy Act ,
Compliance ,
Economic Sanctions ,
Employee Training ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Risk Assessment ,
Sanction Violations ,
U.S. Treasury
This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence -
On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more
2/8/2019
/ China ,
Cosmetics ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Goods or Services ,
Imports ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain