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Financial Crimes

K2 Integrity

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

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On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

Thomas Fox - Compliance Evangelist

TD Bank, Part 6 – Caremark Claims – The Board of Directors

Today, I continue my exploration of the TD Bank AML/BSA enforcement action through two of the most significant cases regarding Boards of Directors and corporate compliance: the Caremark and Stone v. Ritter decisions. The...more

Ballard Spahr LLP

Bank Policy Institute Critiques Notice of Proposed Rulemaking to Modernize AML/CFT Programs

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The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of...more

The Volkov Law Group

TD Bank’s Rotten Corporate Culture — From its Store-Level Operations to its Board’s Audit Committee (Part IV of IV)

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TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more

Troutman Pepper

Upcoming Corporate Transparency Act Compliance Deadlines

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As we are now in the fourth quarter of 2024, it is crucial for business owners to focus on the upcoming Corporate Transparency Act (CTA) reporting deadlines and to take the necessary steps to ensure compliance. The CTA is...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 3 – Lessons Learned for Compliance

We continue our exploration of the resolution of the AML/BSA enforcement action involving the TD Bank US (the Bank) wholly owned by the TD Bank Group, a publicly traded (NYSE: TD) international banking and financial services...more

The Volkov Law Group

TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV)

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“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors,...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

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On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 2 – When Profits Trump Compliance: A Recipe for Corporate Disaster

We continue our exploration of the resolution of the AML/BSA enforcement action involving TD Bank US (the Bank), which is wholly owned by TD Bank Group, a publicly traded (NYSE: TD) international banking and financial...more

Awatif Mohammad Shoqi Advocates & Legal...

UAE Strengthens Anti-Money Laundering Framework: Key Updates and Amendments

The UAE has reinforced its commitment to combating financial crime with significant updates to its anti-money laundering (AML) legislation. Federal Decree-Law No. 20/2018, which originally established the framework for...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

Ballard Spahr LLP

FinCEN Withdraws Designation of ABLV Bank as Foreign Financial Institution “Of Primary Money Laundering Concern”

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A Gesture Providing Limited Solace to a Now-Defunct Bank - Six years ago, in early 2018, we blogged about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (“FinCEN’s”) designation of ABLV Bank, AS...more

Buckingham, Doolittle & Burroughs, LLC

Upcoming Deadline for Beneficial Ownership Information Reports Under the Corporate Transparency Act (CTA)

Effective January 1, 2024, the Corporate Transparency Act (the “Act”) requires many U.S. businesses to disclose information regarding their beneficial owners. Failure to comply with the Act can result in significant civil and...more

Seyfarth Shaw LLP

FinCEN's October 2024 Beneficial Ownership Information FAQ Update

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On October 3, 2024, the Financial Crimes Enforcement Network (FinCEN) issued new guidance concerning the Corporate Transparency Act (CTA) by updating and expanding on the Beneficial Ownership Information (BOI) Reporting...more

Verrill

CTA Compliance Check-In #2

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In June we circulated an article entitled “Mid-year assessment: Are you in good shape on CTA compliance?” The Corporate Transparency Act (CTA) deadline for filing BOI reports with FinCEN is now less than three months away –...more

Burr & Forman

Corporate Transparency Act Filing Deadlines Approaching - What You Need to Know, Part I

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The Corporate Transparency Act (CTA) requires “reporting companies” to report certain beneficial ownership information (BOI) to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) in order to enhance...more

WilmerHale

Nick Ephgrave’s First Year as SFO Director

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Nick Ephgrave QPM, the Director of the Serious Fraud Office (“SFO”), recently marked the end of his first year in office. Ephgrave has brought a renewed energy, sense of purpose and proactive approach to the SFO, opening six...more

Ankura

Banking as a Service: How Strong Is Your Financial Crime Compliance Partnership?

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The growth in partnerships between banks and Fintech companies through Banking as a Service (BaaS) models presents significant opportunities for innovation across the financial services sector. However, these collaborations...more

King & Spalding

FCA Fines Starling Bank Over Financial Sanctions Screening Failures

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On 27 September 2024, the Financial Conduct Authority (“FCA”), imposed a financial penalty of approximately £29 million on the British bank – Starling Bank Limited (“Starling”) – for failings related to its financial crime...more

Epstein Becker & Green

Corporate Transparency Act’s January 1, 2025, Deadline Looms for Reporting Companies Existing Prior to 2024

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The reporting requirements of the Corporate Transparency Act (CTA), included as part of the Anti-Money Laundering Act of 2020, went into effect on January 1, 2024, and certain deadlines of January 1, 2025, are fast...more

Wilson Sonsini Goodrich & Rosati

Important Filing Deadline: The U.S. Corporate Transparency Act

As we approach the final quarter of 2024, we wanted to remind you of the rapidly approaching deadline for the new Beneficial Ownership Information (BOI) reporting requirements under the U.S. Corporate Transparency Act (CTA)....more

Ballard Spahr LLP

FinCEN Reports Check Fraud Amounting to $688 Million Over Six Month Period

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The Financial Crimes Enforcement Network (“FinCEN”) issued last month an in-depth report on check fraud stemming from mail theft (“Report”).  This is a pernicious and expanding problem.  The Report follows upon a joint alert...more

Proskauer Rose LLP

Regulation Round Up - September 2024

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Welcome to the UK Regulation Round Up, a regular bulletin highlighting the latest developments in UK and EU financial services regulation....more

Polsinelli

Court Challenge to Corporate Transparency Act Rebuffed – For Now

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On September 20, 2024, U.S. District Judge Michael H. Simon for the District of Oregon issued an Opinion and Order in favor of defendants in the case. Firestone, et al.. v Janet Yellen, et al., Case No. 3:24-cv-1034 (D. Ore.)...more

Kilpatrick

Corporate Transparency Act Beneficial Ownership Report Filing Deadline for Companies Formed Before This Year is January 1, 2025 |...

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As we have previously reported, the federal Corporate Transparency Act (CTA) requires most privately held companies organized in the U.S. and foreign companies that register to do business in a U.S. state to file an online...more

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