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]
On 26 February 2025, the Financial Conduct Authority (FCA) published a portfolio letter (Letter) explaining its supervision priorities for the asset management and alternatives portfolios....more
On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s...more
The January 1, 2025, deadline imposed by the Corporate Transparency Act (CTA) for all “reporting companies” formed prior to 2024 to file their initial beneficial ownership reports with FinCEN is rapidly approaching. Given the...more
The recent ruling by the U.K. Court of Appeal declared that the U.K. National Crime Agency’s decision not to investigate the importation of cotton produced through the use of Uyghur forced labor in China was unlawful. This...more
In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more
The Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations are fundamental components of the financial industry’s efforts to combat financial crimes. As a BSA/AML Officer, it is crucial to ensure that your...more
Melissa Duffy and Trevor Coval contributed their thought leadership to the American Conference Institute’s 14th Annual Global Encryption, Cloud & Cyber Export Controls Conference, held in San Francisco on May 14-16. Melissa...more
The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more
On February 28, 2024, the Biden Administration issued Executive Order (EO) 13873, focused on restricting certain transactions involving Americans' personal data, as well as sensitive government data, to specific countries....more
Our last two alerts in this series covered key considerations for early-stage companies in the alternative protein industry and provided an overview of financing in the alternative protein industry. This alert follows those...more
Know Your Customer (KYC) is a fundamental process used by Financial Institutions (FIs) to verify the identities of their customers and assess the associated financial crime risk. Its primary goal is to prevent money...more
In the world of international finance and crime, criminals and terrorists have always sought innovative ways to launder money and avoid sanctions. One relatively recent method that has gained prominence is known as...more
The UAE has demonstrated a strong commitment to combating money laundering, terrorist financing and the financing of unlawful organizations. This commitment is reinforced by Federal Decree-Law No. 20/2018 and its amendments,...more
Enforcement and legal risks relating to sanctions compliance remain high and all firms should continue to exercise care in meeting regulatory expectations. The promulgation of new sanctions relating to Russia has slowed but...more
Differences in law as well as cultural differences can prolong international aircraft transactions. Assembling a good team of legal and technical professionals, as well as an aircraft broker familiar with international...more
Introduction: Influx of Information Triggers Threats to Anti-Money Laundering Compliance - Information abounds. The internet, social media, and web 3.0 are full of content and it’s available with a few finger taps....more
As the European Union has made continued progress toward implementing a holistic human rights legislative agenda, the United States, in the wake of the recent second Summit for Democracy, began to push its own set of human...more
With the ever-increasing use of sanctions as a foreign policy tool (or weapon), sanctions compliance has taken on greater importance than ever. Moreover, as countries increase extraterritorial applications of their sanctions,...more
For the first time, companies providing virtual currency services will be required to comply with Israeli anti-money laundering provisions. This follows an amendment to the Prohibition of Money Laundering Order that recently...more
From manufacturers to financial and other professional service providers, no prudent company welcomes attention based upon an unfortunate client or customer affiliation. Still, in our media-saturated world, “foreign” and...more
For years, the cryptocurrency wallets of U.S. taxpayers have existed in a reporting gray zone. However, as it becomes clear that crypto asset transactions are not slowing down, the Internal Revenue Service (IRS) has signaled...more
El aumento de los costos de cumplimiento, las estructuras de clientes corporativos difíciles de entender, las multas y sanciones, el cambio de la responsabilidad corporativa a la responsabilidad individual y las...more
With the global economy reeling from the direct effects of the COVID-19 pandemic, no sector is spared from its impact, including the art market. As auction houses seek to find ways to sustain business during this time of...more
In the context of COVID-19, there are significant challenges involved in conducting due diligence: hard-copy documents are inaccessible, in-person meetings have moved online, and on-site visits may be impossible....more
The introduction of the Fifth Money Laundering Directive on the 10th January 2020 brought the art market into the fold of regulated sectors for anti-money laundering purposes. The new law, which amends the existing...more