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Office of Foreign Assets Control (OFAC) Financial Institutions FinCEN

Ballard Spahr LLP

FinCEN Issues Supplemental Advisory on Fentanyl Distribution and Growing Role of Transnational Criminal Organizations

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On June 20, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplemental advisory to alert U.S. financial institutions about emerging trends in the illicit fentanyl supply chain. The supplemental advisory...more

White & Case LLP

The Shadow Financial System

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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

Ballard Spahr LLP

FinCEN and SEC Propose Rulemaking Requiring CIP for Investment Advisers

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On May 13th, the Financial Crimes Enforcement Network (FinCEN) and the Securities Exchange Commission (SEC) issued a joint notice of proposed rulemaking (NPRM) that would require SEC-registered investment advisers (RIAs) and...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

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

Bass, Berry & Sims PLC

Swiss Finance Company to Pay Almost $4 Million for Sanctions Violations

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On March 14, the U.S. Treasury Department, Office of Foreign Assets Control (OFAC) announced that EFG International AG (EFG), a Switzerland-based bank, had agreed to pay roughly $3.74 million to settle allegations that it had...more

Foodman CPAs & Advisors

BOI Acceso Y Salvaguardas

El 2/20/23, FinCEN publicó la Guía de Cumplimiento para Pequeñas Entidades para los requisitos de Acceso y Salvaguardas de la información sobre los Beneficiarios Finales. La Guía de BOI Acceso y Salvaguardas (de seis páginas...more

Foodman CPAs & Advisors

BOI Access & Safeguards

On 2/20/23, FinCEN published the Small Entity Compliance Guide for Beneficial Ownership Information Access and Safeguards Requirements. The (six-pages and four sections) BOI Access & Safeguards Guide provides an overview...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Paul Hastings LLP

Daily Financial Regulation Update -- Tuesday, January 30, 2024

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January 29, 2024- The U.S. Department of the Treasury issued a finding and notice of proposed rulemaking (NPRM) that identifies an Iraqi bank that serves as a conduit for terrorist financing, as a foreign financial...more

Jenner & Block

Client Alert: How Regulatory Events of 2023 Should Guide Financial Institutions' New Year's Resolutions for 2024

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As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more

Sheppard Mullin Richter & Hampton LLP

OFAC Sanctions Crypto Mixer Following Allegations of Laundering Funds to North Korea

The U.S. authorities are increasingly taking actions against big-name crypto mixers for potential violations of sanctions regulations. On November 29, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control...more

Foodman CPAs & Advisors

Financiamiento Del Terrorismo: Señales De Alerta De FinCEN

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El 20/10/23, FinCEN emitió Señales de Alerta (“Red Flags”) sobre el Financiamiento del Terrorismo para ayudar a las instituciones financieras a identificar flujos de financiamiento para la organización terrorista Hamás en...more

Foodman CPAs & Advisors

Terrorist Financing FinCEN Red Flags

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On 10/20/23, Terrorist Financing Red Flags were issued by FinCEN to assist financial institutions in identifying funding streams for the terrorist organization Hamas in response to Hamas’s terrorist attack on the people of...more

American Conference Institute (ACI)

Navigating U.S. Sanctions and Export Control Restrictions

Over the last several months, companies have become entangled in an increasingly complex web of new and expanded sanctions and export control restrictions related to Russia in response to its war on Ukraine. The current...more

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

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Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - October 2023 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Ballard Spahr LLP

SEC Exam Priorities Target AML

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Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Morrison & Foerster LLP

Enforcement Alert: FinCEN Leverages “Gap Rule” for Violations of the Bank Secrecy Act

On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its first “Gap Rule” enforcement action in a Consent Order with Bancrédito International Bank and Trust...more

American Conference Institute (ACI)

[Event] 2nd Forum on Digital Assets Compliance: AML, Sanctions and Regulatory Oversight - October 17th - 18th, New York, NY

With so many new, emerging risks coming to the forefront, ACI is excited to announce our Digital Assets Compliance: AML, Sanctions and Regulatory Oversight. Unlike other conferences, this highly anticipated event stands apart...more

Ballard Spahr LLP

FinCEN Analysis Reveals Patterns and Trends in Suspected Evasion of Russia-Related Export Controls

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Following Russia’s invasion of Ukraine, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert and a supplemental alert (the...more

Skadden, Arps, Slate, Meagher & Flom LLP

In Coordinated Action, US Authorities Increase Russia-Related Restrictions and Warn About Evasion Risks

Through a series of coordinated actions in May 2023, the United States launched a whole-of-government effort to expand and strengthen enforcement of its sanctions campaign against Russia as the conflict in Ukraine continues...more

Venable LLP

U.S. Imposes Additional Sweeping Sanctions on Russia in Coordination with G7 Countries

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On May 19, 2023, the United States, in coordination with the G7 and other international partners, imposed significant new sanctions on Russia aimed to further degrade the Russian Federation's capacity to wage war against...more

K2 Integrity

Sanctions Against Russia: Recent Developments - May 2023

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K2 Integrity delivers information and analysis on recent developments related to sanctions against Russia and key implications for the public, private, and non-profit sectors as the United States (U.S.), the European Union...more

Husch Blackwell LLP

BIS Implements Additional Export Controls and Entity List Additions Targeting Russia to Align with Allies and Partners

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On May 19, 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) announced new export controls and Entity List additions during President Biden’s G7 visit in Japan. In conjunction with the G7 meetings,...more

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