News & Analysis as of September 21, 2024

Bank Secrecy Act › Enforcement

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The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -

Federal Reserve Board Issues Cease and Desist Order Against Banking-As-A-Service Provider

Sheppard Mullin Richter & Hampton LLP on 7/2/2024

On June 14, the Federal Reserve Board (Fed) released a cease and desist order against an Arkansas-based banking-as-a-service (BaaS) provider for compliance and risk management failures. As part of the order, the bank is...more

CryptoLink - May 2024 Updates

Akin Gump Strauss Hauer & Feld LLP on 6/13/2024

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's May...more

FDIC Issues Orders Against Two More Banks Over Fintech Partnerships

Sheppard Mullin Richter & Hampton LLP on 4/15/2024

In the FDIC’s latest monthly update on enforcement decisions and orders, the agency published recent consent orders it entered against both a New York-based and an Ohio-based bank, the latest in the agency’s series of...more

PPP Lender Liability, Enforcement, & Fintech Challenges

Buchalter on 12/29/2023

The Paycheck Protection Program (“PPP”) emerged as a lifeline for small businesses grappling with the unprecedented challenges of the COVID-19 pandemic. Lenders navigated a landscape of regulations that Congress quickly...more

Mapping Future Enforcement in US Gaming Law Based on Recent UK Enforcement

Perkins Coie on 7/12/2023

Regulated gaming is booming in the United States. This is particularly true of newer forms of gambling, such as skill games, fantasy sports, and social casino games played on the internet and mobile applications. In fact,...more

Crypto in a Time of Uncertainty

K2 Integrity on 6/15/2023

On 07 June 2023, K2 Integrity hosted a webinar on the state of cryptocurrency and digital assets in a rapidly evolving regulatory landscape. A discussion was held with Bryan Stirewalt, senior managing director at K2...more

Biden Administration Offers More Details on Emerging Crypto Regulatory Scheme

ArentFox Schiff on 9/30/2022

The Biden Administration, after ordering a series of reports on the risks and potential benefits of cryptocurrency and digital assets in its March 9, 2022, Executive Order (EO), has now published the “Comprehensive Framework...more

[Event] Canadian Forum on Global Economic Sanctions - September 22nd - 23rd, Toronto, ON, Canada

American Conference Institute (ACI) on 8/10/2022

The Canadian Institute’s 7th Annual Canadian Forum on Global Economic Sanctions returns to Toronto in-person and via livestream on September 22-23! Join a Canadian and international faculty of government of officials,...more

Cryptocurrency - Compliance Matters

Mintz on 8/3/2022

July was a hot month for crypto enforcement, but August is off to a hot start in its own right. On August 2, 2022, the New York State Department of Financial Services (the “Department”) issued a Consent Order with Robinhood’s...more

Keeping up with Anti-Money Laundering Rules

Venable LLP on 7/27/2022

In 1970, Congress passed the Currency and Foreign Transactions Reporting Act, commonly known as the “Bank Secrecy Act” (BSA). The BSA is often referred to as an “anti-money laundering” (AML) law or jointly as “BSA/AML.” The...more

Prosecution Of NY Lender Marks Shift In PPP Enforcement

Bradley Arant Boult Cummings LLP on 4/20/2022

Until recently government enforcement and regulatory scrutiny of fraud and other misconduct relating to COVID-19 relief programs were generally limited to end recipients of the relief. These efforts have mostly been...more

Biden Administration Prioritizes Increased and Broadened Anti-Corruption Enforcement

Bracewell LLP on 6/10/2021

On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity,...more

[Virtual Event] Asia Pacific Conference on Economic Sanctions Compliance and Enforcement - May 27th - 28th, 9:00 am - 1:15 pm SGT

American Conference Institute (ACI) on 4/5/2021

ACI’s Asia-Pacific Advanced Conference on Economic Sanctions Compliance and Enforcement is the largest sanctions gathering in Asia for financial institutions and global exporters. This unique conference features senior...more

CFTC Throws its Hat into the Corporate Compliance Arena

Sheppard Mullin Richter & Hampton LLP on 9/16/2020

On September 10, 2020, the Commodities Futures Trading Commission (CFTC) issued the latest in a series of circulars regarding corporate compliance released this summer by government agencies. In June, the Criminal Division of...more

Should You Bank a Virtual Currency Business?

Ward and Smith, P.A. on 9/28/2018

Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more

Anti-Money Laundering Obligations for Virtual Currency Companies

Wilson Sonsini Goodrich & Rosati on 4/4/2018

Virtual currency businesses are under scrutiny by U.S. anti-money laundering (AML) regulators. Earlier this year, U.S Treasury Secretary Steven Mnuchin emphasized that virtual currencies are subject to AML regulations. He...more

With Another Veteran Criminal Prosecutor At FinCEN’s Helm, Aggressive AML Enforcement Expected To Continue

Fox Rothschild LLP on 11/9/2017

Today the U.S. Department of the Treasury announced Kenneth A. Blanco as Director of the Financial Crimes Enforcement Network (FinCEN), a bureau in Treasury’s Office of Terrorism and Financial Intelligence. The leading...more

Financial Services Weekly News - October 2016 #3

Goodwin on 10/27/2016

Editor's Note - Another Cybersecurity Proposal. On the heels of the New York State Department of Financial Services (NYDFS) issuing its proposed regulation that would require banks and insurance companies to institute...more

New York DFS Issues $180M BSA/AML Penalty

Manatt, Phelps & Phillips, LLP on 9/22/2016

New York’s banking regulator cracked down on enforcement of the state’s anti-money laundering (AML) law, issuing a $180 million penalty against Mega International Commercial Bank of Taiwan (Mega Bank) for past violations and...more

Is New York's Proposal a Harbinger of Things to Come? Certification of BSA/AML Compliance and Personal Liability for Mistaken or...

Manatt, Phelps & Phillips, LLP on 1/12/2016

Why it matters - The New York Department of Financial Services (DFS) may have launched its strongest offensive yet against observed shortcomings in the Bank Secrecy Act and anti-money laundering (BSA/AML) compliance...more

BSA, AML Failures by West Virginia Bank Yield FDIC, FinCEN, DOJ Actions

Manatt, Phelps & Phillips, LLP on 7/8/2015

Why it matters - In a coordinated effort, the U.S. government identified another “poster child” to demonstrate its continued vigilance and earnestness in pursuing lax BSA/AML procedures and oversight and violations of...more

FinCEN Reasserts its Commitment to Casino Oversight and Enforcement

McGuireWoods LLP on 7/7/2015

In a recent post we described a number of steps taken over the last year by the primary federal regulator for casinos – the Financial Crimes Enforcement Network (FinCEN) – that should cause casino operators to have Title 31...more

AML Compliance Expectations Unabated—Fines, Enforcement Actions and a Deferred Prosecution Agreement Against Banks, Money...

Manatt, Phelps & Phillips, LLP on 6/25/2015

Why it matters - Three Financial Crimes Enforcement Network (FinCEN) orders, three sets of fines and asset forfeitures, a deferred prosecution agreement and one bank enforcement action demonstrate the resolve of the...more

Financial Services Weekly News Roundup - June 2015 #3

Goodwin on 6/18/2015

Regulatory Developments - CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more

Why Should Americans Care About the FIFA Indictments? Part I – Only the US Government Could Do It

Thomas Fox - Compliance Evangelist on 6/8/2015

A colleague recently posed that question to me. I thought it was an interesting one and although at first blush the response to me might appear self-evident, the fact that it was posed means that my view may not be universal....more

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Bank Secrecy Act › Enforcement

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