One Note Samba
The Panama Papers - What the Fallout Means for U.S. Companies and Professionals
The Panama Papers & The Tempo of International Corruption Cases
On August 27, 2024, the New York State Department of Financial Services (“NYDFS”) announced a consent order involving a $35 million settlement with Nordea Bank Abp (“Nordea”) for alleged significant failures related to...more
The British Virgin Islands (“BVI”) is a small chain of islands in the Caribbean situated between Puerto Rico and St. Maarten. The BVI has been a top sailing destination since the days of Sir Francis Drake. The BVI is a...more
The UK Government has published draft Money Laundering Regulations 2017 alongside a consultative document. Publication of the draft Regulations follows a consultation launched by HM Treasury on September 15, 2016, entitled...more
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more
After the Panama Papers, and with the recent FinCEN final Customer Due Diligence (CDD) rule, U.S. financial institutions are further focused on tightening internal controls against money laundering, terrorist financing,...more
The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more
FinCEN’s new CIP beneficial owner rules may hinder the ability of shell and nominee companies to directly access the US financial system without disclosing the natural persons who own 25% or more of the company. Pooled...more
In an apparent effort to create the impression of strong U.S. policy response in the wake of the Panama Papers, the U.S. Department of the Treasury (Treasury) announced three initiatives to promote greater transparency and...more
Under the dark cover of the Panama Papers scandal, FinCEN moved quickly to issue its beneficial; ownership regulations. For all of the US regulatory and financial industry bluster, it is about time. The United States stands...more
On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued the final version of its long-awaited “Customer Due Diligence Rules” under the Bank Secrecy Act. The final rules impose a new requirement on...more
The idea that a “fifth pillar” of Anti-Money Laundering (“AML”) compliance – customer due diligence requiring U.S. banks, broker-dealers, mutual funds, commodity futures merchants, and introducing brokers (“covered financial...more
On 21 April 2016, the Government released its new Action Plan for anti-money laundering (AML) and counter-terrorist finance (CTF). The Action Plan contains a number of AML/CTF proposals on which the UK Government wishes to...more
The New Register - From 6 April 2016, most UK companies, LLPs and Societas Europaea became required to maintain a register of “persons with significant control” (PSCs). A PSC is defined as an individual who ultimately...more