News & Analysis as of

Patriot Act Financial Transactions

Orrick, Herrington & Sutcliffe LLP

The CFTC Begins Policing AML Enforcement

Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town.  The Commodity Futures Trading Commission recently finished its fiscal year with...more

Orrick, Herrington & Sutcliffe LLP

New Syria, North Korea and Other Sanctions Provisions Enacted as Parts of the National Defense Authorization Act for Fiscal Year...

On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more

Ballard Spahr LLP

FinCEN Identifies Iran as a Jurisdiction of Primary Money Laundering Concern

Ballard Spahr LLP on

On October 25, 2019, FinCEN issued a final rule imposing the Fifth Special Measure against the Islamic Republic of Iran as a “jurisdiction of primary money laundering concern” (“Final Rule”) under Section 311 of the USA...more

Ballard Spahr LLP

D.C. Circuit Rules in Favor of Broad Reach of Patriot Act Subpoenas

Ballard Spahr LLP on

On August 6, the U.S. Court of Appeals for the District of Columbia kept in place $50,000-per-day fines on three Chinese banks—whose identities are redacted—for refusing to comply with subpoenas issued by the Department of...more

The Volkov Law Group

Anti-Money Laundering Risks for Global Companies (Part I of III)

The Volkov Law Group on

Non-financial institution companies operating in the global marketplace face ever-increasing risks of money laundering. Sophisticated criminal organizations have developed their own mechanisms and strategies to skirt money...more

Ballard Spahr LLP

FinCEN Fines Texas Bank $2M for Alleged Failure to Vet and Monitor Mexican Correspondent Banking Relationship – But Touts Bank’s...

Ballard Spahr LLP on

FinCEN recentlty announced entry of a $2 million assessment against Lone Star National Bank, a private bank operating out of Texas, for the bank’s allegedly willful violations of the Bank Secrecy Act (“BSA”) and inadequate...more

Skadden, Arps, Slate, Meagher & Flom LLP

After Nearly 20 Years, US Lifts Burma Sanctions

After nearly two decades, the United States has formally ended economic sanctions on Burma (Myanmar). Citing substantial efforts undertaken to promote democracy, President Barack Obama issued an executive order, on October 7,...more

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