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]
Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
Our downloadable report, Legal Insights for Manufacturing, explores how the business, legal, and regulatory framework is evolving—and will evolve—to address the large generational shifts taking place. This year, our report...more
OFAC continues its enforcement push. At the same time, OFAC is managing a complex, global set of sanctions against Russia. DOJ has promised to increase prosecution of global banks for sanctions violations....more
Key Takeaways - On October 3, 2021, the International Consortium of Investigative Journalists released the “Pandora Papers,” which expose the use by political leaders, billionaires, and others of offshore entities in an...more
We all have been following the rapid growth of cryptocurrency and the creation of lucrative trading platforms. Cryptocurrency has earned the scrutiny of regulators and criminal prosecutors – not for run-of-the-mill fraud...more
The CFTC recently joined the host of other federal and state regulators who enforce anti-money laundering laws, by bringing three cases finding violations of CFTC Regulation 42.2. Regulation 42.2 requires futures commission...more
DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more
Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town. The Commodity Futures Trading Commission recently finished its fiscal year with...more
On October 8, 2020, Attorney General William Barr announced the release of a Cryptocurrency Enforcement Framework produced by the Department of Justice (DOJ) Cyber-Digital Task Force. The 83-page framework is intended to help...more
How can a compliance professional navigate an increasingly complex sanctions landscape around a best practices sanctions compliance program and what happens if there is a compliance failure? I recently visited with Adam Frey,...more
On Sunday June 21, 2020, the Mexican Banking and Securities Commission ("CNBV") ?in charge of the anti-money laundering and counter-financing of terrorism ("AML/CFT") supervision of the banking sector in Mexico? communicated...more
Compliance management has moved from being a nice to have, to an absolute need to have. For many organizations, it is part of business-as-usual (BAU). The scale and scope of compliance frameworks across the world have grown,...more
I. Background - Sweden’s financial supervisory authority (“SFSA”) recently fined Swedbank AB a record 4 billion Swedish kronor (approximately $386 million) for deficiencies in its anti-money laundering (“AML”) processes...more
Compliance has been pushed more to the forefront in anti-money laundering (AML). As banking institutions, financial institutions and the financial services industries continue to tighten and strengthen AML controls, criminals...more
On 6 November we held a breakfast seminar focusing on the most important sanctions issues affecting the City and how to manage compliance with different financial sanctions regimes effectively. ...more
What have been some of the advancements in compliance this century? One of the key recent innovations has been the role of Artificial Intelligence (AI) in compliance going forward. LawTech had disrupted the legal profession...more
I am in a multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand and implement some of the key concepts of the Framework into your...more
Last week, British Arab Commercial Bank (BACB), located in the United Kingdom, agreed to settle an OFAC enforcement action for $4 million. ...more
Recent conversations with firms have left me in a curious state of mind, I had thought all financial services firms had wrapped their Know Your Customer (KYC) programs and put them to bed?…. It turns out I was wrong!...more
Standard Chartered Bank certainly has its troubles. You know a company is in trouble, however, when it breathes a sigh of relief after paying nearly $1.1 billion in fines and penalties and compares itself to BNP Paribas, the...more
Last week, the Financial Action Task Force (“FATF”) issued a report concluding that Mexico needs to “step up efforts in pursuing money launderers.” ...more
Global companies should incorporate AML risks into their risk analysis of their third-party distributors, agents and other intermediaries. The basic questionnaire, due diligence risk analysis, contractual provisions,...more
Non-financial institution companies operating in the global marketplace face ever-increasing risks of money laundering. Sophisticated criminal organizations have developed their own mechanisms and strategies to skirt money...more
On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more