News & Analysis as of September 25, 2024

Bank Secrecy Act

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

Blockchain and Digital Assets News and Trends - August 2024

DLA Piper on 9/3/2024

This monthly bulletin is designed to help companies identify important legal developments governing the use and acceptance of blockchain technology, smart contracts, and digital assets....more

Nevada Gaming Control Board Alleges Casino AML Failures Based on Wagering of Customers Involved in Illegal Bookmaking

Ballard Spahr LLP on 8/27/2024

The Nevada Gaming Control Board (“Board”) recently filed a complaint (“Complaint”) against Resorts World Las Vegas casino (“Resorts World”), alleging that, despite repeated red flags, Resorts World’s Anti-Money Laundering...more

Broker Dealer Regulatory Digest - February 2024

Davis Wright Tremaine LLP on 2/23/2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Multiple Billions – While its Founder, Owner and...

Ballard Spahr LLP on 11/27/2023

As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more

Client Alert: New multi-front Enforcement Action Emphasizes Key AML Compliance Requirements

Jenner & Block on 10/12/2023

Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more

FinCEN Issues $15 Million Dollar Civil Penalty Against Shinhan Bank America for Alleged Failure to Implement and Maintain...

Ballard Spahr LLP on 10/10/2023

On September 29, the Financial Crimes Enforcement Network (“FinCEN”) entered into a consent order with Shinhan Bank America (“SHBA”), which imposed a $15 million dollar civil penalty against SHBA for allegedly willfully...more

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2023 # 2

Troutman Pepper on 9/12/2023

To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Finance Services industry over the past week...more

In the First Use of Its Section 9714 Powers, the U.S. Treasury Designated Bitzlato as a Russian-Linked Primary Money Laundering...

Skadden, Arps, Slate, Meagher & Flom LLP on 2/7/2023

On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more

Potential BSA/AML Roadmap – Crypto Exchange Bittrex Enforcement Actions

Harris Beach PLLC on 11/17/2022

The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) settled enforcement actions with Washington state-based Bittrex. In the two settlements, Bittrex...more

OFAC and FinCEN Announce First Parallel Enforcement Actions in the Virtual Currency Space

Skadden, Arps, Slate, Meagher & Flom LLP on 11/16/2022

On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more

Major U.S. Crypto Exchange Consents to $29 Million Penalty for Historic BSA and OFAC Violations

BakerHostetler on 10/25/2022

On October 11, 2022, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced a $29 million civil monetary penalty against Bittrex, a...more

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

Ballard Spahr LLP on 10/21/2022

The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

SEC Continues Use of Data Analytics to Aid Enforcement Investigations

Holland & Knight LLP on 7/29/2022

The U.S. Securities and Exchange Commission (SEC) charged nine individuals with insider trading in three separate actions on July 25, 2022, alleging the misconduct resulted in ill-gotten gains totaling more than $6.8 million....more

Recent Enforcement Actions Indicate Heightened Scrutiny of BSA/AML Compliance and Digital Assets

Harris Beach PLLC on 6/20/2022

Recent enforcement actions against banks indicate a new regulator emphasis on digital assets and Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. Last year, Anchorage Digital Bank (Anchorage)—formerly Anchorage...more

OCC and FinCEN Issue $200 Million in Penalties for BSA-AML Violations

Sheppard Mullin Richter & Hampton LLP on 3/29/2022

On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent...more

OCC and FinCEN Issue $9 Million in Penalties for BSA-AML Violations

Sheppard Mullin Richter & Hampton LLP on 12/23/2021

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) and the Financial Crimes Enforcement Network (“FinCEN”) issued civil monetary penalties against a Texas community bank for violations of the Bank...more

U.S. Federal Regulators Turn Up the Heat on Cryptocurrency Trading Platforms

Proskauer - The Capital Commitment on 8/27/2021

With new types of digital assets and related business on the rise, federal authorities have been busy investigating. Recently, the SEC, FinCEN and the CFTC have imposed some notable settlements involving cryptocurrency...more

The Distributed Ledger: Blockchain, Digital Assets and Smart Contracts - August 2021

Skadden, Arps, Slate, Meagher & Flom LLP on 8/27/2021

This issue discusses a variety of legal, regulatory and enforcement developments in the digital asset space in the U.S. and Europe, including expanded reporting requirements for broadly defined cryptocurrency “brokers,” a...more

Off‐Shore Crypto Exchange to Pay Up to $100 Million to Resolve Enforcement Action with U.S. Regulators

Orrick, Herrington & Sutcliffe LLP on 8/20/2021

The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more

Closer Scrutiny Expected of Corporate Conduct

Skadden, Arps, Slate, Meagher & Flom LLP on 4/30/2021

The Biden administration is widely expected to be tougher on corporate wrongdoing than its predecessor. Although there have not yet been significant changes to existing policies, key nominations to date and early enforcement...more

The Anti-Money Laundering Act of 2020: A Survey of Key Provisions and Practice Takeaways

Perkins Coie on 4/13/2021

On New Year’s Day 2021, Congress overrode a presidential veto to pass the Anti-Money Laundering Act of 2020 (AMLA 2020), which amends and modernizes the Bank Secrecy Act (BSA). The AMLA 2020 includes sweeping reforms updating...more

SEC’s Division of Examinations Signals Continuing Focus on Broker-Dealer AML Compliance Obligations

Jones Day on 4/12/2021

The Situation: The Securities and Exchange Commission’s Division of Examinations ("EXAMS") released a Risk Alert on March 29, 2021, reminding broker-dealers of their obligation to comply with anti-money laundering ("AML")...more

FinCEN’s $390 Million case against Capital One – And What it Means for AML Enforcement

Proskauer - The Capital Commitment on 3/26/2021

As the financial services industry prepares for expanded criminal and civil enforcement under the Bank Secrecy Act (“BSA”) with the passage of the Anti-Money Laundering Act of 2020, FinCEN’s recent case against Capital One...more

Credit Union’s Marijuana-Related Compliance Failure is a Warning to Lenders

Troutman Pepper on 3/19/2021

Live Life Federal Credit Union, a $69 million-asset credit union based in Fraser, Michigan, recently consented to a cease-and-desist order issued by the National Credit Union Administration Board (NCUA). The enforcement...more

Treasury’s New Bank Secrecy Act Whistleblower Program

Buchalter on 1/26/2021

In perhaps the last major legislative action under this presidential administration, on New Year’s Day 2021, Congress passed—over President Trump’s veto—what could be the most significant anti-money laundering (AML) statute...more

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