News & Analysis as of

Filing Requirements Suspicious Activity Reports (SARs)

Freiberger Haber LLP

Enforcement News: Broker-Dealers Settle Charges for Filing Deficient SARs

Freiberger Haber LLP on

The Bank Secrecy Act (“BSA”) and implementing regulations promulgated by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) require that broker-dealers file a suspicious activity report (SAR”) with...more

K2 Integrity

AML/CFT Rules for Investment Advisers

K2 Integrity on

On 12 June 2024, K2 Integrity and Schulte Roth & Zabel hosted a webinar discussing new regulatory obligations anticipated under proposed rules for investment advisers (IAs), timelines for finalization and compliance, and how...more

Fox Rothschild LLP

IRS Issues New Guidance for Cannabis Companies That Receive Over $10K in Cash

Fox Rothschild LLP on

The IRS’s Office of Chief Counsel recently published a memorandum providing information for cannabis companies struggling to comply with the completion of Form 8300, which must be filed every time a company receives a cash...more

Perkins Coie

Blockchain Week in Review - January 2021

Perkins Coie on

Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Ballard Spahr LLP

Guilty Pleas Highlight Illicit Funneling of Chinese Cash to Casinos

Ballard Spahr LLP on

Government Suggests that Unusual Pleas are Just the Tip of an Iceberg - Chinese law generally prohibits its citizens from converting more than $50,000 in Chinese yuan into foreign currency in a year.  On Monday, two men...more

Ballard Spahr LLP

Court Decision Reinforces SAR Obligations of Penny Stock Clearing Brokers

Ballard Spahr LLP on

Second Post in a Two-Part Series - Opinion Stresses Importance of Narrative Sections and Supporting Documentation for SARs - In our first post in this series, we discussed the Securities and Exchange Commission’s...more

Ballard Spahr LLP

Practical Tips for Ensuring Your AML Program Withstands the Scrutiny of Regulators

Ballard Spahr LLP on

First Post in a Two-Part Series - How do financial institutions get in trouble with their regulators? Recent AML enforcement actions suggest that the following two failures are at the heart of most of these actions: (1)...more

Ballard Spahr LLP

FinCEN Director Addresses Virtual Currency and Touts Regulatory Leadership and Value of SAR Filings

Ballard Spahr LLP on

Address Emphasizes Role of SARs in Fighting Illegal Activity, Including Drug Dealing Fueling the Opioid Crisis - Kenneth Blanco, the Director of the Financial Crimes Enforcement Network (“FinCEN”), discussed last week...more

A&O Shearman

Company Settles With The SEC For Allegedly Failing To File Required Suspicious Activity Reports

A&O Shearman on

On July 2, 2018, the Securities and Exchange Commission (“SEC”) filed a one-count complaint in District Court for the Northern District of California against Charles Schwab Corp. (“Schwab” or the “Company”) for allegedly...more

Ballard Spahr LLP

Ninth Circuit Court of Appeals Outlines BSA Compliance Obligations and How One Small Bank Failed to Meet Them

Ballard Spahr LLP on

The Tale of an AML BSA Exam Gone Wrong - As we have blogged, the Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease...more

Ballard Spahr LLP

FINCEN Advises That Participation in a Foreign Tax Regularization Program By Itself Does Not Trigger SAR Filing Obligation

Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) recently advised that a financial institution is not required to file a Suspicious Activity Report (“SAR”) based solely upon a customer’s inquiry into or participation in a...more

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

Baker Donelson on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

K&L Gates LLP

AML Update: The Rumors Are True – FinCEN Proposes Regulations That Will Require SEC Registered Investment Advisers to Adopt an AML...

K&L Gates LLP on

On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more

The Volkov Law Group

The 5 Most Common AML Compliance Program Deficiencies

The Volkov Law Group on

Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance...more

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