All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
The Finnish government has unveiled a draft law proposing a major overhaul of the country's gaming regulatory landscape. The proposed system, targeted for launch in January 2027, would usher in a new era of open competition...more
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
There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more
Last week, the United States Attorney’s Office for the Southern District of New York unsealed an indictment against global cryptocurrency exchange KuCoin and two of its founders, Chun Gan and Ke Tang, for allegedly conspiring...more
DeFi development carried quietly on throughout 2023, but DeFi protocols also faced significant hurdles. In the US, the Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) increased their...more
In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more
Companies are increasingly choosing not to pay ransom for ransomware and extortionware due to the growing associated risks. In fact, a recent report by crypto-crime analyst firm Chainalysis found that payments to threat...more
The past year has seen a flurry of crypto-related activities by the federal financial regulators, including the issuance of reports, guidance, joint statements, and interpretive letters....more
Key Takeaways - ..The Joint Chiefs of Global Tax Enforcement (J5) issued its first intelligence bulletin providing guidance to banks, law enforcement partners and private investigators regarding indicators of potential...more
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more
Key developments of interest over the last month include: United Kingdom: HM Treasury responds to Payments Landscape Review call for evidence Hong Kong: HKMA publishes white paper exploring the idea of a CBDC Italy: Bank of...more
On August 10, 2021, the Commodity Futures Trading Commission (CFTC) and the Financial Crimes Enforcement Network (FinCEN) announced a near-record settlement of $100 million with BitMEX, a cryptocurrency derivatives exchange....more
As cryptocurrency’s market cap surpasses the $2.5 trillion mark and continues to climb, global regulators have turned their attention to understanding and addressing the risks surrounding digital assets. In recent years,...more
Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more
Just before the Christmas holidays, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued proposed rulemaking entitled “Requirements for Certain Transactions Involving Convertible Virtual...more
The UK Financial Conduct Authority (FCA) has become the anti-money laundering and countering the financing of terrorism (AML/CFT) supervisor for some types of cryptoasset businesses. These will need to meet certain...more
U.S. Developments - Regulatory Developments - CFTC Announces Two Events Designed to Encourage FinTech Innovation - On June 27, 2019, the Commodity Futures Trading Commission (“CFTC”) announced two events designed to...more
The Financial Crimes Enforcement Network (FinCEN) is the U.S. Treasury Department bureau charged with monitoring financial transactions in order to combat domestic and international money laundering, terrorist financing and...more
Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more
Virtual currency businesses are under scrutiny by U.S. anti-money laundering (AML) regulators. Earlier this year, U.S Treasury Secretary Steven Mnuchin emphasized that virtual currencies are subject to AML regulations. He...more
This week, the U.S. Senate Committee on the Judiciary and the U.S. Senate Committee on Banking, Housing and Urban Affairs held hearings focused in part on Anti-Money Laundering (“AML”) and the Bank Secrecy Act (“BSA”)....more
Last week, Circle announced major changes to its application and platform. While many focused on Circle’s decision to cut its users’ ability to buy and sell Bitcoin, the breaking news may have been its decision to create a...more
FinCEN focus requires major shift in gaming business practices - Which complex, global industry where billions of dollars exchange hands every day, and where high-net-worth customers park significant sums, is facing...more
Powerful new computational technology pioneered in e-commerce presents Chinese regulators with potential concerns and solutions to the perennial problem of information, pricing, and settlement capacity. Online payment...more