News & Analysis as of

Customer Due Diligence (CDD) Economic Sanctions

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Orrick, Herrington & Sutcliffe LLP

FinCEN and Commerce Dept. urge monitoring of Russian export control evasion attempts

On May 19, FinCEN and the Department of Commerce’s Bureau of Industry and Security (BIS) issued a supplemental joint alert urging continued vigilance for potential Russian export control evasion attempts...more

Goodwin

The FCA’s 2023/24 Priorities for UK Payments: Firms and Investors, Take Note

Goodwin on

On March 16, 2003, the UK Financial Conduct Authority (FCA) published its letter Portfolio Letter: FCA priorities for payments firms to the CEOs of UK Payment Institutions (PIs), Electronic Money Institutions (EMIs), and...more

The Volkov Law Group

Addressing Beneficial Ownership Requirements in Your Compliance Program (Part I of IV)

The Volkov Law Group on

We repeatedly hear about the importance of beneficial ownership, and the requirement that companies confirm beneficial ownership of its third-parties, vendors and suppliers.  At the same time, there is increasing pressure...more

Foodman CPAs & Advisors

Deficiencies or Weaknesses in an OFAC Sanctions Compliance Program can lead to OFAC Administrative Actions

On May 2, 2019, OFAC (Office of Foreign assets Control) published guidance titled “A Framework for OFAC Compliance Commitments”.  The purpose of the OFAC Framework guidance is to encourage a “risk-based” approach to...more

Ballard Spahr LLP

AMA Updates AML Best Practices for AML Compliance

Ballard Spahr LLP on

AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more

K2 Integrity

China Emerging as an Increasing Driver of Global Illicit Finance Risk

K2 Integrity on

Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more

Alston & Bird

Venezuela Executive Order Regulatory Update

Alston & Bird on

The new sanctions announced by the Trump administration freeze all Venezuelan government assets in the United States and allow the Treasury Department to sanction any person, business or other entity that assists the Maduro...more

WilmerHale

Anti-Money Laundering and Sanctions: Trends and Developments Emerging Under the Trump Administration

WilmerHale on

Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

The Volkov Law Group

Addressing AML Risks in the Era of Aggressive Enforcement

The Volkov Law Group on

The resurgence in anti-money laundering enforcement in the last few years reflects the overall improvement in the banking industry and recovery from the financial collapse. Federal prosecutors and regulators have renewed...more

Holland & Knight LLP

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

Holland & Knight LLP on

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

Skadden, Arps, Slate, Meagher & Flom LLP

"FinCEN Finalizes Customer Due Diligence Rule Amid Other Actions to Enhance Financial Transparency"

In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more

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