Is Edward Snowden a Whistleblower?
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more
Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more
Who may be interested: Investment Advisers - Quick Take: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule subjecting certain registered investment advisers (RIAs) and...more
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more
On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more
The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more
Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more
Durante la Conferencia Anual contra el Lavado de Dinero de FIBA (“Financial and International Business Association”) celebrada el 18 al 21 de marzo de 2024 en Miami, Florida, la Directora Gacki de FinCEN discutió las...more
During the FIBA’s (Financial and International Business Association’s) annual anti-money laundering conference held from March 18, 2024, to March 21, 2024 in Miami, Florida, Director Gacki from FinCEN discussed regulatory...more
On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more
On 17 January 2024, K2 Integrity hosted a webinar on FinCEN’s Notice of Proposed Rulemaking on virtual currency mixers and the implications of this first-of-its-kind 311 designation on the virtual currency industry. Elizabeth...more
A proposed rule would increase Treasury’s insight into non-US crypto mixing transactions to combat illicit activities by malicious actors. On October 19, 2023, the US Department of the Treasury’s Financial Crimes...more
Silicon Valley Bank, Santa Clara, California, was closed on March 10 by the California Department of Financial Protection and Innovation (CDFPI). On March 12, the New York State Department of Financial Services (NYSDFS)...more
On January 17, 2023, U.S. law enforcement authorities in Miami arrested Anatoly Legkodymov, a Russian national and the founder and majority owner of Hong Kong-based virtual currency exchange Bitzlato Ltd., on charges of money...more
In 1970, Congress passed the Currency and Foreign Transactions Reporting Act, commonly known as the “Bank Secrecy Act” (BSA). The BSA is often referred to as an “anti-money laundering” (AML) law or jointly as “BSA/AML.” The...more
...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more
Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more
With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more
Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more
This coming Saturday is the 20th anniversary of the attacks upon America on September 11, 2001. Like most Americans, this was the seminal event in the history of our country. I have been thinking a lot about that date and the...more
The European Commission, on July 20, 2021, unveiled a landmark legislative proposal that would overhaul the European Union’s approach to anti-money laundering and combatting the financing of terrorism (“AML/CFT”), creating a...more
On June 3, 2021, President Biden issued a National Security Memorandum establishing the fight against corruption both at home and abroad as a core United States national security interest and directing the development of a...more
Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more
The override of former President Trump's veto of the National Defense Authorization Act of 2021 resulted in the enactment of broad amendments to the US anti-money laundering regime. Among the amendments are provisions to...more
In perhaps the last major legislative action under this presidential administration, on New Year’s Day 2021, Congress passed—over President Trump’s veto—what could be the most significant anti-money laundering (AML) statute...more