U.S. and Mexican companies and financial institutions are seeking to navigate AML/CFT, sanctions, export control, and tariff and supply chain concerns as their governments’ make rapid changes around trade and tariffs and ramp...more
The Financial Action Task Force (FATF) has updated its ‘grey list’ of jurisdictions under increased monitoring, removing Senegal and adding Algeria, Angola, Côte d’Ivoire, and Lebanon. The intergovernmental organization made...more
Crypto Product News: BTC/ETH ETNs, Custody, Insurance, Tokenized Treasuries - The London Stock Exchange (LSE) recently published a market notice addressing applications for Bitcoin and Ether exchange traded notes (ETNs),...more
U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds)2 and their U.S. general partners, sponsors, and managers (Advisers) are not directly subject to the Bank Secrecy Act of 1970...more
During K2 Integrity’s 14 March webinar, panelists Chip Poncy and Mohammed Alaa Ghanem discussed the assistance required in Syria and Türkiye in the wake of the 6 February earthquakes; gave an overview of sanctions imposed on...more
On the first anniversary of Russia’s invasion of Ukraine, the United States (U.S.), the European Union (EU), the United Kingdom (UK), the Group of Seven (G7), the Financial Action Task Force (FATF), and other authorities...more
On October 21, 2022, the Financial Action Task Force (FATF) officially moved Myanmar onto the agency’s blacklist, where it joins Iran and North Korea, the only other two listed countries. It is likely that the United States...more
On March 9, 2022, President Joseph Biden issued Executive Order 14067, which charged the Department of Justice (in consultation with the Departments of State, Treasury, and Homeland Security) to submit a report on how to...more
In a series of articles, we discuss recent efforts by U.S. regulators and other bodies to set expectations and standards with respect to cryptocurrencies and other virtual assets and the impact of these efforts on businesses...more
Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more
The Regulation Process for FinCEN’s New Beneficial Ownership Reporting Requirement Launches - The Financial Crimes Enforcement Network (FinCEN) issued an Advanced Notice of Proposed Rulemaking (ANPRM) on Thursday to solicit...more
Recent news coverage has highlighted two potentially watershed moments in the FinTech revolution: the rise of Decentralized Finance (“DeFi”) that challenges both traditional FinTechs and legacy financial institutions alike,...more
On October 8, 2020, the Attorney General’s Cyber-Digital Task Force (“the Task Force”) issued its Cryptocurrency Enforcement Framework (the “Report”), which offers background on virtual assets, enforcement milestones, and...more
Indictment Again Highlights the Role of Correspondent Banking in Money Laundering - On May 28, 2020, the U.S. Department of Justice (“DOJ”) unsealed a 50-page indictment against 28 North Korean and 5 Chinese bankers...more
- Proposed legislation targets current gaps in U.S. financial crime law and enforcement - Bi-partisan Senate legislation would likely expand compliance obligations for banks and others in financial services industry -...more
Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more
In this post, our UK white collar crime partner, Louise Delahunty, considers the potential impact of a possible #Brexit on the UK’s implementation of the 4th Anti-money Laundering Directive; the UK government’s proposed...more