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)
Imagine sitting in your living room, enjoying a cup of your favorite morning coffee, and you open your mail to discover that you recently opened a new bank account at XYZ Bank, unbeknownst to you. Or maybe you receive an...more
On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more
The Anti-Money Laundering Act of 2020 (the “AMLA”), which became law January 2, 2021 with Congress’ override of then President Trump’s veto of the Defense Appropriations Act of 2021 included provisions bringing dealers in...more
Executive Summary - The U.S. Congress recently passed the Corporate Transparency Act (“CTA”) as part of the 2021 National Defense Authorization Act. The CTA requires certain corporations, limited liability companies and...more
The Corporate Transparency Act (CTA), part of the 2021 National Defense Authorization Act enacted into law on January 1, 2021, will impose new beneficial ownership reporting requirements on many companies. The stated purposes...more
On May 1, 2020, the Federal Bureau of Investigation issued an intelligence bulletin warning, reported on in late July by several members of the media, concerning the use by threat actors of the “private placement of funds,...more
A recent report by the U.S. Senate Permanent Subcommittee on Investigations (headlined by Chairman Senator Rob Portman, Republican of Ohio, and Ranking Member Tom Carper, Democrat of Delaware) has drawn widespread attention...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
Global companies should implement an AML program and KYC practices that follow the general outline for best practices, though it does not need to be as rigorous as a financial institution. For most companies, AML risks can...more
Global companies should incorporate AML risks into their risk analysis of their third-party distributors, agents and other intermediaries. The basic questionnaire, due diligence risk analysis, contractual provisions,...more
In May 2016, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its final rule on Customer Due Diligence (CDD) Requirements for Financial Institutions. ...more
Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more