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FATF BSA/AML

Ballard Spahr LLP

FATF Re-Rates United States as “Largely Compliant” with Beneficial Ownership Recommendation

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The Financial Action Task Force (“FATF”) has re-rated the U.S. as “largely compliant” with FATF’s Recommendation 24, which pertains to transparency related to beneficial ownership of legal persons. Specifically, FATF...more

Ballard Spahr LLP

The Basel AML Index: Forfeiture, Non-Profits, Crypto, and More. A Guest Blog.

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Today we are very pleased to welcome, once again, guest blogger Dr. Kateryna Boguslavska of the Basel Institute on Governance (“Basel Institute”), who will discuss the Basel Institute’s release of the 12th annual Public...more

StoneTurn

3 Key Takeaways from FATF’s Recent Mutual Evaluations Report

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The Financial Action Task Force (“FATF”) recently released its Report on the State of Effectiveness and Compliance with the FATF Standards (“Report”). The Report contains the results of its 4th Round of Mutual Evaluations...more

K2 Integrity

Proposal to Revise Recordkeeping and Travel Rule Requirements Poses Implementation Challenges for FIs and VASPs

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The U.S. Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the U.S. Federal Reserve System (FRB) proposed new rules that would expand the applicability of recordkeeping and travel rule requirements,...more

K2 Integrity

FATF Plenary Outcomes: October 21-23, 2020

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Beginning on October 21, 2020, the Financial Action Task Force (“FATF”) held its three-day Plenary meeting virtually. It was the first Plenary of Germany’s two-year Presidency. As part of the Plenary outcomes, the FATF...more

White & Case LLP

FinCEN and US Federal Banking Agencies Clarify Risk-Based Obligations on Politically Exposed Persons

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The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more

Ballard Spahr LLP

Joint Statement Clarifies Due Diligence Expectations for Politically Exposed Persons

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Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more

Ballard Spahr LLP

GAO Publishes Report on Effectiveness of Real Estate GTOs Issued by FinCEN

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Law Enforcement Has Been Using GTO Data - First of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering - The U.S. Government Accountability Office (“GAO”) has issued a report on the status and...more

Hogan Lovells

Financial institutions general regulatory news, July 2020 #2

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LIBOR transition and PRA resolution-related rules: PRA statement - The UK Prudential Regulation Authority (PRA) has published a statement outlining the PRA's view on the implications of LIBOR transition for contracts in...more

Foodman CPAs & Advisors

El FATF identifica las Amenazas de Lavado de Dinero derivadas de la Crisis del Covid-19

En mayo del 2020, el FATF (GAFI) publicó nuevas amenazas y vulnerabilidades de lavado de dinero y financiamiento del terrorismo derivadas de la crisis COVID-19. El documento destaca cómo el fraude, el cibercrimen, la mala...more

Foodman CPAs & Advisors

The FATF identifies Money Laundering Threats arising from the Covid-19 Crisis

On May, 2020, the FATF published new money laundering and terrorist financing threats and vulnerabilities arising from the COVID-19 crisis.  The document highlights how fraud, cybercrime, misdirection of government funding...more

Ballard Spahr LLP

Money Laundering and the Illegal Wildlife Trade

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The Financial Action Task Force (“FATF”) just released an important report entitled Money Laundering and the Illegal Wildlife Trade (the “Report”).  The lengthy and detailed Report makes clear that the IWT is pernicious...more

Orrick, Herrington & Sutcliffe LLP

COVID-19 Creates Increased Risk of Financial Crimes and AML Exposure; FATF and FinCEN Provide Guidance

Earlier this month, senior officials of the global money laundering and terrorist financing watchdog—the Financial Action Task Force (FATF)—issued a paper identifying challenges, good practices, and policy responses to new...more

Foodman CPAs & Advisors

How are Financial Institutions identifying and managing their PEP relationships?

With respect to customers, Financial Institutions are required to have processes in place for identifying Politically Exposed Persons – known as “PEPs”.  ...more

Orrick - On the Chain

FinCEN Sends Message to the Virtual Currency Industry: The Travel Rule Applies to You, Too

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FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more

Ballard Spahr LLP

FinCEN Issues Advisory on Medical Scams Relating to COVID-19

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On May 18, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advisory “to alert financial institutions to rising medical scams related to the COVID-19 pandemic. This [A]dvisory contains red flags, descriptions of...more

Ballard Spahr LLP

FATF Issues Paper on COVID-19 Enhanced AML and Fraud Risks

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On May 4, the Financial Action Task Force (“FATF”) issued a paper entitled “Covid-19-Related Money Laundering and Terrorist Financing – Risk and Policy Responses (“Paper”). ...more

K2 Integrity

Beneficial Ownership: Current Challenges Met with Opportunity

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Beneficial ownership is a topic which presents significant challenges to compliance officers charged with untangling a web of ownership interests that span numerous international jurisdictions and ownership structures. ...more

Ballard Spahr LLP

Financial Action Task Force Grades America’s AML Compliance

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Second Post in a Two-Post Series on Recent FATF Activity - As we just blogged, the Financial Action Task Force (“FATF”) issued a statement from its President on COVID-19 and measures to combat illicit financing during the...more

Ballard Spahr LLP

Financial Action Task Force Update: Statement on COVID-19’s Implications for AML Programs

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First Post in a Two-Post Series on Recent FATF Activity - Members presumably working from home, the Financial Action Task Force (“FATF”) was active last week, first issuing its 3rd Enhanced Follow-up Report & Technical...more

Foodman CPAs & Advisors

The U.S.A Continues to be AML/BSA “Vulnerable”

The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/CFT threats. ...more

Ballard Spahr LLP

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

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In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

Hogan Lovells

G20 calls on countries to adopt FATF crypto standards

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The G20 has urged countries to adopt the Financial Action Task Force (FATF) standards on virtual assets and virtual asset service providers, which were adopted in June last year. ...more

Ballard Spahr LLP

Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key...

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First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more

Ballard Spahr LLP

Trade-Based Money Laundering: GAO Report Stresses Enforcement Challenges

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On January 29, 2020, the U.S. Government Accountability Office (GAO) publicly released the results of a study which the GAO conducted on trade-based money laundering, or TBML, entitled “Countering Illicit Finance and Trade:...more

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