News & Analysis as of September 19, 2024

Enforcement Actions

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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 -

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

The Shadow Financial System

White & Case LLP on 6/18/2024

The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Banking and Consumer Regulatory Digest - March 2024 - 2

Davis Wright Tremaine LLP on 4/17/2024

Editor's Note - 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,...more

[Event] 8th Forum on FinTech & Emerging Payment Systems - April 9th - 10th, New York, NY

American Conference Institute (ACI) on 2/28/2024

ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more

Banking and Consumer Regulatory Digest - February 2024

Davis Wright Tremaine LLP on 2/19/2024

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

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

Jenner & Block on 1/12/2024

As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...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

[Event] 2nd Forum on Digital Assets Compliance: AML, Sanctions and Regulatory Oversight - October 17th - 18th, New York, NY

American Conference Institute (ACI) on 9/25/2023

With so many new, emerging risks coming to the forefront, ACI is excited to announce our Digital Assets Compliance: AML, Sanctions and Regulatory Oversight. Unlike other conferences, this highly anticipated event stands apart...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

Bitzlato Founder Charged With Facilitating Money Laundering of More than $700 Million in Dark Web Funds

White & Case LLP on 2/7/2023

Anatoly Legkodymov, Russian founder of Hong Kong-registered cryptocurrency exchange Bitzlato Limited ("Bitzlato"), was arrested on January 17 based on an Amended Complaint filed by the Department of Justice ("DOJ") charging...more

Banks – What Should You Know? Civil Liability for Failure to Detect Human Trafficking

Moore & Van Allen PLLC on 12/15/2022

In 2020, we wrote about the increased regulatory attention on financial institutions’ obligations to detect and respond to human trafficking. In 2021, we wrote about how anti-human trafficking programs fit squarely in banks’...more

Compliance measures to address sanctions enforcement: ‘the new FCPA’

American Conference Institute (ACI) on 7/12/2022

In line with the Biden administration’s declaration last year that anticorruption is a “core United States national security interest,” sanctions evasion enforcement rapidly has become a core priority for the Department of...more

Nutter Bank Report: October 2021

Nutter McClennen & Fish LLP on 10/28/2021

Federal and State Financial Regulators Publish New Guidance on LIBOR Transition - The federal banking agencies, the NCUA and the CFPB, in conjunction with the state bank and state credit union regulators, have issued joint...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

Fed Proposes Guidelines for Access to Master Accounts and Payment Services

Goodwin on 5/7/2021

In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), in response to an increased number of inquiries and access requests from companies with fintech and other narrow purpose charters, invited...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

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

New Year, New Laws – Congress Passes Major Anti-Money Laundering Act

Snell & Wilmer on 1/18/2021

On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more

SEC Finalizes Reforms Under Investment Advisers Act

Goodwin on 1/7/2021

In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

Congress Makes Sweeping Changes to Money Laundering Enforcement

Buchalter on 1/5/2021

On New Year’s Day 2021, Congress passed—over President Trump’s veto—a defense appropriations law containing the Anti-Money Laundering Act of 2020 (“AML Act”) and the Corporate Transparency Act, as part of a sweeping new set...more

FinCEN Explains What Guides Its Enforcement Decisions

Proskauer - The Capital Commitment on 9/17/2020

On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN), which is the primary regulator and administrator of the Bank Secrecy Act (BSA), issued a statement on enforcement of the BSA. The requirements of the BSA...more

An Interagency Statement from Regulators and a FinCEN Statement provide clarity Regarding Enforcement Actions

Foodman CPAs & Advisors on 9/4/2020

On August 13, 2020, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the Comptroller of the Currency issued a JOINT...more

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

Ballard Spahr LLP on 9/3/2020

Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on 8/28/2020

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

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