News & Analysis as of

Currency Transaction Reports (CTR)

Will Bankers = Law Enforcers on 5/11/18?

by Foodman CPAs & Advisors on

On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018. The CDD Rule applies to Covered Financial Institutions (federally...more

FinCEN Launches “FinCEN Exchange” To Enhance Information Sharing With Financial Institutions

by Fox Rothschild LLP on

The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) launched the “FinCEN Exchange” program today in order to enhance information sharing with financial institutions and to strengthen...more

FDIC Provides Some Statistics on Violations Found During BSA/AML Exams: One Percent of Exams Lead to Formal Enforcement Actions

by Ballard Spahr LLP on

In its Summer 2017 issue of Supervisory Insights, published last week, the Federal Deposit Insurance Corporation (“FDIC”) provides some insight into its examination process and outcomes for Bank Secrecy Act (“BSA”)/Anti-Money...more

Record-Setting Prosecutions in the Money Transmitting Business: Ways to Avoid Compliance Violations

by Blank Rome LLP on

In the first several months of 2017, we have seen significant anti-money laundering settlements and penalties in the money transmitting business arising from lax compliance programs, including the record-setting Western Union...more

Civil Forfeiture Enforcement Under Fire – Part I

by Ballard Spahr LLP on

Forfeiture actions by Internal Revenue Service Criminal Investigation (IRS CI) based on alleged structuring activity have come under fire, yet again. Specifically, the Treasury Inspector General for Tax Administration (TIGTA)...more

European Parliament: The U.S. is a Haven for Tax Cheats and Money Launderers

by Ballard Spahr LLP on

Earlier this week, we blogged about how the United States recently declared the Philippines to be a “major money laundering country.” On the same day of our post, March 7, the European Parliament (EP) issued a Report which...more

2016 Year in Review: Money Laundering (Part Two)

by Ballard Spahr LLP on

In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more

2016 Year End Review: Money Laundering Opinions of Note

by Ballard Spahr LLP on

The federal courts continued in 2016 to produce a stream of cases pertaining to money laundering. We focus on three below because they involve analysis of basic issues that frequently arise in money laundering litigation....more

2016 Year in Review: Forfeiture

by Ballard Spahr LLP on

The field of forfeiture saw significant action in 2016. The IRS offered to return forfeited funds used in structuring, but Congress still may clip its ability to forfeit such funds. Meanwhile, DOJ renewed a controversial...more

De-Risking 101

by Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Cantor Gaming Forced to Pony up Millions for AML Violations: What Lessons Can Be Learned from FinCEN’s Latest Enforcement Action...

by Blank Rome LLP on

Action Item: Licensed gaming and other entities required to comply with the Bank Secrecy Act should be aware of this recent FinCEN enforcement action, and they must ensure that their compliance programs address the lessons...more

Don’t Gamble on Anti-Money Laundering Compliance

by Blank Rome LLP on

In August 2014, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an advisory urging leadership within all U.S. financial institutions to actively promote a culture of compliance...more

FinCEN Proposes AML Program Requirement for Banks without a Federal Functional Regulator

by Goodwin on

FinCEN has proposed extending its anti-money laundering (AML) program requirement for banks to banks that are not subject to regulation by a federal functional regulator, including state chartered limited purpose trust...more

FinCEN Assesses Significant Penalty Against Casino for Bank Secrecy Act Violations

by Holland & Knight LLP on

The Financial Crimes Enforcement Network (FinCEN) assessed on July 15 a civil money penalty in the amount of $2.8 million against Hawaiian Gardens Casino Inc., d/b/a The Gardens Casino, for Bank Secrecy Act (BSA) regulatory...more

Asset Forfeiture Reform Bill Moving Through Congress

by BakerHostetler on

The “Restraining Excessive Seizure of Property through the Exploitation of Civil Asset Forfeiture Tools Act” (tortuously abbreviated as the RESPECT Act) (H.R. 5523) continues to make its way through Congress, with a markup ...more

White Collar & Investigations: Hastert Receives 15 Month Sentence in Federal Structuring Case

by Williams Mullen on

In June of last year former Speaker of the United States House of Representatives Dennis Hastert was indicted for structuring and false statements to the FBI in an investigation that focused on more than $900,000 in cash...more

United States District Court Pushes Back Against Government in North Carolina Asset Forfeiture Case

by Williams Mullen on

In May of last year we highlighted the decision by the United States Attorney for the Eastern District of North Carolina to dismiss a forfeiture case he’d brought against Lyndon McLellan, the owner of a small convenience...more

FinCEN Imposes New Reporting Requirements on New York and Miami Real Estate Markets

by McGuireWoods LLP on

The Financial Crimes Enforcement Network (FinCEN) recently announced two geographic targeting orders (GTOs) imposing new reporting and recordkeeping requirements on title insurance companies operating in New York City and...more

FinCEN Announces First Card Club AML Enforcement Action

by McGuireWoods LLP on

Just in time for Christmas, the Financial Crimes Enforcement Network (FinCEN), the financial industry (including casinos and card clubs) regulator, announced its first-ever enforcement action against a card club, California’s...more

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

by Morrison & Foerster LLP on

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Investment Management Update - October 2015

by Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Advisers Charged with Cleansing Dirty Money from Industry

by Baker Donelson on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

FinCEN Seeks to Add Investment Advisers to BSA/AML Regulation

Why it matters - More than 12 years after initially proposing to extend the Bank Secrecy Act's anti-money laundering compliance programs and recordkeeping and reporting requirements to investment advisers, the Financial...more

FinCEN Proposed AML Rule For Investment Advisers

by Foley Hoag LLP on

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more

"A Long Time Coming: FinCEN Proposes AML Program and SAR Requirements for Investment Advisers"

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would impose certain anti-money laundering (“AML”) requirements on...more

38 Results
|
View per page
Page: of 2
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.