How Will the Anti-Money Laundering Act of 2020 and the Corporate Transparency Act Impact Banks’ Anti-Money Laundering Compliance Under the Bank Secrecy Act? A Discussion with Guest Matt Haslinger
Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)
Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more
In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...more
On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more
On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more
On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...more
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
On February 14, the Conference of State Bank Supervisors commented that FinCEN should be more explicit in its inclusion of state regulators as agencies that can request access to FinCEN’s forthcoming secure, non-public...more
There is cautious optimism that 2022 will be the year that federal legislation will open the door to the banking of cannabis transactions. But is the Safe Banking Act the answer? On the latest episode of #CreditEcotoGo with...more
On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more
In recent years, the financial services industry has seen an exponential growth in the popularity of challenger banks in the UK. Digitally-driven, technologically innovative and efficient onboarding processes are some of the...more
The Canadian Institute’s 20th Canadian Annual Forum on AML and Financial Crime is a curated program, dedicated to addressing pressing industry challenges through in-depth analysis of the financial crime landscape and industry...more
On 2 February 2021, the Financial Conduct Authority (the FCA) published a report on the U.K. unsecured credit market (the Woolard Report), which makes several recommendations designed to generate alternatives to high-cost...more
UK payment systems: Pay.UK recommendations for adopting ISO 20022 - Pay.UK published a report containing conclusions and recommendations relating to adopting the common global messaging standard for UK payments, known as...more
...On June 29, the Financial Crimes Enforcement Network (FinCEN) issued guidance (the “June guidance”) to “address questions related to Bank Secrecy Act/Anti-Money Laundering (BSA/AML) regulatory requirements” for providing...more
On 30 April 2020, the FCA released a statement announcing a six-month extension to the deadline for firms’ implementation of strong customer authentication (SCA) for e-commerce under the Payment Services Regulations 2017...more
For financial services firms understanding who the Ultimate Beneficial Owner (UBO) of a corporation is has become a central compliance task. As Ellen Lafferty explains in this podcast and in the new edition of The Complete...more
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
Examples of good and poor practices provide helpful guidance, and a reminder of supervisory expectations. The FCA has published TR18/3, setting out the findings from its thematic review of the anti-money laundering (AML)...more
As you are aware, FinCEN’s Customer Due Diligence rules are effective in two days. In a nutshell, these rules require banks to obtain and verify the identity of the beneficial owners of new business customers. The rules are...more
On April 19, 2018, the European Parliament (“EP”) adopted the European Commission’s (the “Commission”) proposal for a Fifth Anti-Money Laundering Directive (“AMLD5”) to prevent terrorist financing and money laundering through...more
Interagency Statement on Accounting and Reporting Implications of the New Tax Law - On January 18, 2018, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal...more
Luxembourg recently published two important bills to combat money laundering and terrorism financing – one transposes the EU AML4 Directive1 into Luxembourg law; the second establishes a central register of beneficial owners,...more