Navigating New Compliance Challenges: The Impact of the Money Transmitter Modernization Act on Payroll Processing - Payments Pros – The Payments Law Podcast
• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more
As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more
For the second straight year, the majority of whistleblower tips received by the Commodity Futures Trading Commission (CFTC) Whistleblower Program were related to cryptocurrency fraud. On October 31, the CFTC released its...more
On February 21, the Illinois Department of Financial and Professional Regulation (IDFPR) announced several legislative initiatives to establish consumer protections for cryptocurrencies and other digital assets and provide...more
Continuing with both its crackdown on cybercriminals and illicit digital marketplaces, along with its continued economic pressure on the Russian Federation, OFAC has sanctioned two entities that fit both criteria. On April...more
Payoneer, Inc., an online money transmitter and prepaid access company, agreed to pay $1.4 million to OFAC to settle violations of multiple sanctions programs. ...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
MoneyGram settled with OFAC for $34,329 for 359 sanctions programs violations. MoneyGram is a global payments service. According to OFAC, the 359 transactions totaled $105,627 in value and were processed on behalf of...more
The incoming Biden team will need to quickly address significant digital asset issues, including a major enforcement action and a significant proposed FinCEN rule initiated in the final days of the outgoing administration. ...more
In a lesson to everyone that the use of foolish monikers will come back to haunt you, Kais Mohammad, 36, a.k.a. “Superman29,” has met his Kryptonite - the U.S. Department of Justice. ...more
According to one blockchain and cryptocurrency security firm, this year is on pace to be the second highest in cryptocurrency theft, hacking and fraud, with January through May 2020 already seeing $1.36 billion stolen in...more
Virtually attend the forum to learn how to align your compliance program with the amended Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) regulations effective 2020/2021. In June 2019 amended...more
Indictment Alleges that Bank and its Officers Used Front Companies to Evade Prohibitions on Iran’s Access to the U.S. Financial System - The U.S. Attorney for the Southern District of New York has charged Turkish state-owned...more
FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more
The Situation: The Financial Crimes Enforcement Network ("FinCEN") released interpretive guidance concerning the application of the Bank Secrecy Act ("BSA") and the anti-money laundering ("AML") regulations to certain...more
A few days before thousands of blockchain industry participants poured into New York for “Blockchain Week,” the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on virtual currencies...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more
Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more
First Post in a Two-Part Series - Recent actions in the crypto realm demonstrate that authorities and regulators have not slackened their commitment to applying and enforcing Anti-Money Laundering (“AML”) laws and...more
The Consumer Financial Protection Bureau (CFPB) is not the only consumer watchdog keeping a close eye on the financial sector and certainly not the only agency focused on FinTech. This is also a key area for the Federal Trade...more
Last week, the Financial Crimes Enforcement Network (FinCEN) backed up its strong public statements about enforcing the anti-money laundering (AML) laws with respect to cryptocurrency by bringing an enforcement action against...more
Last week, the Financial Crimes Enforcement Network (FinCEN) announced its first-ever civil penalty against a cryptocurrency exchanger for willful violations of the Bank Secrecy Act (BSA). According to the FinCEN Assessment...more
On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) announced its first enforcement action against a peer-to-peer virtual currency exchanger....more
• On October 11, 2018, FinCEN released an advisory to help U.S. financial institutions better detect potentially illicit transactions related to Iran. • The advisory describes how Iran attempts to access the international...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