News & Analysis as of

Money Laundering Compliance Suspicious Activity Reports (SARs)

Holland & Knight LLP

FinCEN Issues Proposed Rule Amending Requirements of Financial Institutions' AML/CFT Programs

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more

Dorsey & Whitney LLP

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

Dorsey & Whitney LLP on

Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

Guidepost Solutions LLC

Innovate or Incriminate: Safeguarding Financial Institutions from Money Laundering Risks

What You Need to Know - In October 2023, the Department of Treasury’s Office of Foreign Asset Control (OFAC) enacted multiple sanctions targeting the supply chain of fentanyl and other illicit drugs. In addition to...more

The Volkov Law Group

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

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The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals.  ...more

The Volkov Law Group

The Transformative Role of “National AML Priorities” for Compliance in the AML Act of 2020

The Volkov Law Group on

It would be the height of folly to claim that a single theme dominates the AML Act of 2020 (Act). The new law, enacted on January 1 of this year, is an extraordinarily wide-ranging and long overdue reform of the Bank Secrecy...more

Society of Corporate Compliance and Ethics...

Leaked documents reveal how entities evaded sanctions

Report on Supply Chain Compliance 3, no. 19 (October 1, 2020) - Leaked documents from the Financial Crimes Enforcement Network, including a trove of suspicious activity reports, show how nation-states and entities use...more

The Volkov Law Group

United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures

The Volkov Law Group on

Compliance professionals face extraordinary risks – not just for the enterprise but personal risks.  CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more

WilmerHale

W.I.R.E Debates: Law Commission Proposals on Suspicious Activity Reporting

WilmerHale on

The UK Law Commission has published a report criticising existing anti-money laundering legislation and providing recommendations to improve the quality of Suspicious Activity Reports (SARs).  What should we make of these...more

Eversheds Sutherland (US) LLP

Application of FinCEN’s regulations to certain business models involving convertible virtual currencies

On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) issued interpretive guidance1 summarizing the application of the Bank Secrecy Act (BSA) rules to business models “involving money transmission denominated in...more

The Volkov Law Group

UBS Pays $15 Million for AML Compliance Deficiencies

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UBS Group agreed to pay a combined $15 million penalty to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”)and the SEC for regulatory deficiencies in its anti-money laundering compliance program. ...more

Thomas Fox - Compliance Evangelist

Dance Dance Dance in Denmark with the Ghosts of Money Laundering Past

As early as 2007 the Russian Central Bank warned Danske about suspicious activity. In the same year the Estonian banking regulator warned the bank about suspicious transactions. In 2009 an internal whistleblower alerted the...more

The Volkov Law Group

AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions

The Volkov Law Group on

Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations.  With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more

The Volkov Law Group

The Need for Anti-Money Laundering Regulatory Reform

The Volkov Law Group on

It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious. Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML...more

The Volkov Law Group

AML Regulation and Compliance Trends

The Volkov Law Group on

Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more

The Volkov Law Group

DOJ Continues Run on Individual FCPA Criminal Prosecutions

The Volkov Law Group on

The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of...more

A&O Shearman

Financial crime and investigations update for UK corporates

A&O Shearman on

The law and practice relating to financial crime and investigations is evolving fast. In the past 18 months we have seen two new Acts aimed at combatting financial crime (including the creation of two new corporate criminal...more

K&L Gates LLP

Is Money Being Laundered Through Your Financial Institution Using Daily Fantasy Sports Sites?

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This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more

Ballard Spahr LLP

Investment Management Update - October 2015

Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Troutman Pepper

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

Troutman Pepper on

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

Baker Donelson on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

K&L Gates LLP

AML Update: The Rumors Are True – FinCEN Proposes Regulations That Will Require SEC Registered Investment Advisers to Adopt an AML...

K&L Gates LLP on

On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more

The Volkov Law Group

FinCEN Proposes to Apply AML/BSA Requirements to Investment Advisers

The Volkov Law Group on

FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...more

Stinson - Corporate & Securities Law Blog

FinCEN Proposes Extending Anti-Money Laundering Compliance Requirements to Investment Advisers

On Tuesday, the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would require SEC-registered investment advisers, including private equity and hedge funds, to comply...more

The Volkov Law Group

The 5 Most Common AML Compliance Program Deficiencies

The Volkov Law Group on

Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance...more

The Volkov Law Group

Rolling the Dice: Casinos, FinCEN and AML Compliance

The Volkov Law Group on

FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML...more

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