In Short -
The Situation: Terrorists may be increasingly turning to cryptocurrencies to evade sanctions and finance terrorist acts, as recent prosecutions and reports suggest. Under the Antiterrorism Act ("ATA"), as...more
The U.S. Supreme Court unanimously decided Twitter v. Taamneh, clarifying the meaning of key provisions in the Anti-Terrorism Act ("ATA") and the pleading standard for aiding-and-abetting claims under that law....more
In 2022, anti-money laundering ("AML") and sanctions controls were at the center of regulatory and enforcement activities in the United States and abroad. Globally, governments have continued to recognize the impact of AML...more
In Short -
The Situation: In October 2022, the U.S. Department of Justice ("DOJ" or "Department") announced a guilty plea in its first-ever corporate "material support" prosecution under 18 U.S.C. § 2339B of the...more
JASTA's stated intention is to provide litigants "with the broadest possible basis" for relief against entities that have "provided material support, directly or indirectly, to foreign organizations or persons that engage in...more
2021 was a precedent-setting year for anti-money laundering (“AML”) enforcement and legislation. The digital assets industry continued to grow exponentially, driving the associated AML risks to the forefront of regulatory...more
3/10/2022
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Corruption ,
Cryptoassets ,
Economic Sanctions ,
Financial Crimes ,
FinCEN ,
Justice Against Sponsors of Terrorism Act (JASTA) ,
Terrorist Financing Regulations ,
Virtual Currency
The Situation: Many banks and other businesses face lawsuits under the Anti-Terrorism Act ("ATA") seeking to hold them liable for providing services to customers with varying degrees of often-attenuated connections to...more
2020 witnessed a flurry of anti-money laundering activity, with the issues and developments continuing to be global in scope. In the United States, suspicious activity reports, outlining transactions involving terrorism...more
The Situation: The U.S. Department of Justice ("DOJ") has issued guidance revising its 2016 voluntary disclosure policy to provide companies stronger incentives to voluntarily self-report apparent potentially willful trade...more
1/13/2020
/ Cooperation ,
Corporate Counsel ,
Criminal Investigations ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Export Controls ,
FCPA Corporate Enforcement Policy (CEP) ,
Foreign Corrupt Practices Act (FCPA) ,
New Guidance ,
Non-Prosecution Agreements ,
Self-Reporting ,
Voluntary Disclosure ,
White Collar Crimes