Questions of which, if any, regulatory regimes apply to the variety of participants in the cryptocurrency market continue to dog the industry. On February 28, 2022, whether a cryptocurrency futures trading platform...more
First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more
The Tale of an AML BSA Exam Gone Wrong -
As we have blogged, the Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease...more
3/21/2018
/ Appeals ,
Banking Sector ,
BSA/AML ,
Cease and Desist ,
Cooperative Compliance Regime ,
FDIC ,
FFIEC ,
Filing Requirements ,
Financial Institutions ,
Internal Controls ,
Money Laundering ,
Risk Management ,
Suspicious Activity Reports (SARs)
The Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease and desist order against California Pacific Bank (the “Bank”)...more
3/20/2018
/ Administrative Law Judge (ALJ) ,
Appeals ,
Banking Sector ,
Banks ,
BSA/AML ,
Cease and Desist ,
Constitutional Challenges ,
FDIC ,
FFIEC ,
Money Laundering ,
Regulatory Violations ,
Suspicious Activity Reports (SARs)
Attorney General Sessions Announces Rescission of Obama Administration Policies on Marijuana Enforcement; Financial Institutions Lose Grounds to Permit Financial Transactions with Marijuana Businesses....more
1/5/2018
/ Banking Sector ,
BSA/AML ,
Cole Memorandum ,
Criminal Prosecution ,
Decriminalization of Marijuana ,
Department of Justice (DOJ) ,
Dispensaries ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Marijuana ,
Marijuana Related Businesses ,
Medical Marijuana ,
Money Laundering ,
Policy Memorandums ,
Regulatory Standards ,
Suspicious Activity Reports (SARs) ,
Trump Administration
Part Three of a Three-Part Series -
In the third and final part of this series on marijuana-related businesses (“MRBs”), we explore how the Securities and Exchange Commission (“SEC”) and the Department of Justice (“DOJ”)...more
7/13/2017
/ Banking Sector ,
BSA/AML ,
Department of Justice (DOJ) ,
Dispensaries ,
Financial Institutions ,
Investment ,
Marijuana ,
Marijuana Related Businesses ,
NYSE ,
Retail Market ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Violations ,
Trading Platforms ,
Unregistered Securities