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Financial Institutions Currency Transaction Reports (CTR)

Seward & Kissel LLP

Q&A on FinCEN’s New AML Requirements for Certain Investment Advisers

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more

Ballard Spahr LLP

FinCEN Releases Year-in-Review for FY 2023: SARs, CTRs and Information Sharing

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The Financial Crimes Enforcement Network (“FinCEN”) has issued its Year in Review for FY 2023 (“YIR”). It consists of five pages of infographics. According to FinCEN’s press release...more

Foodman CPAs & Advisors

Tarjetas Pasaporte De EE.UU. – Aviso De FinCEN Sobre Fraude

El 15 de abril de 2024, FinCEN, junto con el Servicio de Seguridad Diplomática (“DSS”) del Departamento de Estado de EE.UU., emitió una advertencia sobre el fraude con tarjetas pasaporte de EE.UU. mediante un Aviso a las...more

Foodman CPAs & Advisors

U.S. Passport Card Fraud FinCEN Notice

On 4/15/24, FinCEN in conjunction with the U.S Department of State’s Diplomatic Security Service (DSS), issued warning regarding U.S. Passport Card Fraud via Notice to financial institutions urging them to be vigilant in...more

Ballard Spahr LLP

FinCEN Issues Notice on Counterfeit Passport Card Fraud

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The Financial Crimes Enforcement Network (“FinCEN”) has issued a Notice on the Use of Counterfeit U.S. Passport Cards to Perpetrate Identity Theft and Fraud Schemes at Financial Institutions (“Notice”), asking financial...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Financial Institution Officers

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The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Ballard Spahr LLP

FinCEN Issues Notice on Payroll Tax Evasion and Workers’ Compensation Fraud in the Construction Industry

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The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice entitled “FinCEN Calls Attention to Payroll Tax Evasion and Workers’ Compensation Fraud in the Construction Sector” (the “Notice”). According to the...more

Ballard Spahr LLP

FinCEN Round Up:  FY 2022 in Review; First AML Enforcement Against a Trust Company; and Comments to Congress

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Last week, FinCEN “communicated,” so to speak, to private industry, law enforcement, regulators, and legislators in three very different ways: through a FY 2022 Year In Review infographic; a first-of-its kind enforcement...more

Foodman CPAs & Advisors

When Are Casinos Financial Institutions?

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According to the IRS and FinCEN, Casinos licensed to do business as casinos and which have gross annual gaming revenues in excess of $1,000,000 are Financial Institutions subject to the requirements of the Bank Secrecy Act,...more

Ballard Spahr LLP

AML Act Deadlines Through January 1, 2022 – A Daunting List

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The Financial Crimes Enforcement Network (“FinCEN”) recently complied with two important deadlines under the Anti-Money Laundering Act (“AML Act”) — issuing national priorities for AML and countering the financing of...more

K2 Integrity

Training and Developing a Culture of Compliance

K2 Integrity on

With tightening budgets, increasing regulatory expectations, and a growing number of risks, compliance teams at financial institutions face big challenges as they work to fulfill their mission to mitigate financial crimes and...more

Ballard Spahr LLP

Review, then Reform? AMLA Charts a Path for the Future of SARs and CTRs

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Eighth Blog Post in an Extended Series on Legislative Changes to the BSA/AML Regulatory Regime - As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) contains major changes to the Bank Secrecy Act (“BSA”),...more

Foodman CPAs & Advisors

The BSA Casts A Wider Net

On  September 15, 2020,  FinCEN issued a Final Rule stating that Banks lacking a Federal Functional Regulator will be required to establish and implement AML programs including policies and procedures,  a dedicated compliance...more

Alston & Bird

FinCEN Signals BSA/AML Regulatory Reform

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The Financial Crimes Enforcement Network takes the first of likely many steps to reform the outdated Bank Secrecy Act / Anti-Money Laundering regulatory scheme. Our Financial Services & Products and White Collar, Government &...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

Stinson LLP

Missouri Financial Institutions Must Prepare for Impending Marijuana Banking Challenges

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In November 2018, Missouri voters passed Amendment 2, setting in motion state regulated medical marijuana. Over the last month, the Missouri Department of Health & Senior Services (DHSS) began approving license applications...more

Burr & Forman

FinCEN Announces Civil Monetary Penalty for Virtual Currency Exchanger

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On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) announced its first enforcement action against a peer-to-peer virtual currency exchanger....more

K2 Integrity

A Winning Anti-Money Laundering Strategy: Strengthen Your Defense Against Financial Crimes

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The stakes are high in combating global financial crime. If criminals succeed in hiding ill-gotten gains, they can continue to commit crimes and finance terrorism. ...more

Ballard Spahr LLP

FinCEN, OCC and FBI Offer Diverging Views on AML Reform in U.S. Senate Testimony

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First Post in a Two-Part Series - Late last week, the U.S. Senate Committee on Banking, Housing, and Urban Affairs (the “Banking Committee”) met in open session to conduct a hearing on “Combating Money Laundering and Other...more

Ballard Spahr LLP

FinCEN Director Continues to Push Value of SARs and Other BSA Data

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As we just blogged, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco recently touted the value of Suspicious Activity Reports (“SARs”) in the context of discussing anti-money laundering (“AML”)...more

Foodman CPAs & Advisors

Did you know that Casinos are Financial Institutions?

Since 1985, Casinos that have Gross Annual Gaming Revenues in excess of $1,000,000 are considered to be Financial Institutions and are subject to the requirements of the Bank Secrecy Act (BSA). ...more

Ballard Spahr LLP

Congress Contemplates Broad AML/BSA Reform

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As we blogged earlier this week, Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), in committee in the Senate.  The CTIFA proposes the most substantial overhaul to the Bank...more

Foodman CPAs & Advisors

Will Bankers = Law Enforcers on 5/11/18?

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On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018. The CDD Rule applies to Covered Financial Institutions (federally...more

Fox Rothschild LLP

FinCEN Launches “FinCEN Exchange” To Enhance Information Sharing With Financial Institutions

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The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) launched the “FinCEN Exchange” program today in order to enhance information sharing with financial institutions and to strengthen...more

Ballard Spahr LLP

FDIC Provides Some Statistics on Violations Found During BSA/AML Exams: One Percent of Exams Lead to Formal Enforcement Actions

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In its Summer 2017 issue of Supervisory Insights, published last week, the Federal Deposit Insurance Corporation (“FDIC”) provides some insight into its examination process and outcomes for Bank Secrecy Act (“BSA”)/Anti-Money...more

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