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Policies and Procedures BSA/AML

Ankura

Quality Control Unveiled: Insights from Transaction Monitoring

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Ensuring high-quality standards in any organization is an essential ingredient that must be rooted within a company’s Quality Management Program (QMP) – a program that creates a framework to ensure quality....more

K2 Integrity

[Webinar] Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now? - January 15th,...

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Investment advisers and others involved in the implementation of the new IA AML mandate have been alert to potential ramifications to the rule due to the upcoming change in administration. Upon review, K2 Integrity and...more

Ankura

Identity Theft and How To Prevent It

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Imagine sitting in your living room, enjoying a cup of your favorite morning coffee, and you open your mail to discover that you recently opened a new bank account at XYZ Bank, unbeknownst to you. Or maybe you receive an...more

Foodman CPAs & Advisors

Model 1 FFI’s Obtain Extension of Relief

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IRS issued Notice 2024-78 on 10/28/24 providing the extension of temporary relief for FATCA Model 1 Financial Institutions (FFI’s) regarding the reporting of U.S. Taxpayer Identification Numbers. This means that the temporary...more

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

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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

Guidepost Solutions LLC

Crypto Crackdown: 8 Key BSA/AML Fundamentals for FinTechs

In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

King & Spalding

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

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The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: A Look at the Treasury Department’s April 2023 Report on Decentralized Finance or “DeFi”

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The report examines the vulnerabilities in DeFi, including potential gaps in the United States’ Bank Secrecy Act/anti-money laundering regulatory, supervisory, and enforcement regimes for DeFi. We first discuss how Treasury...more

BakerHostetler

$3.6 Billion Reasons to Up Cryptocurrency Compliance: FBI Cracking Down on Crypto Criminals

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Key Takeaways - ..Banks and cryptocurrency exchanges need to update their BSA programs to account for the unique aspects of cryptocurrencies, detect and report related suspicious activity, and minimize the risk of...more

Oberheiden P.C.

5 Anti-Money Laundering Compliance and Defense Tips

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1. AML Laws - Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more

Katten Muchin Rosenman LLP

Businesses Must Prepare For Expansive AML Reporting of Beneficial Ownership Interests

As covered in our earlier advisory, "AML Enforcement Continues to Trend in 2021," the recently passed National Defense Authorization Act for fiscal year 2021 included the Anti-Money Laundering Act of 2020 (AML Act), which...more

Foodman CPAs & Advisors

The BSA Casts A Wider Net

On  September 15, 2020,  FinCEN issued a Final Rule stating that Banks lacking a Federal Functional Regulator will be required to establish and implement AML programs including policies and procedures,  a dedicated compliance...more

Kramer Levin Naftalis & Frankel LLP

OCIE Releases 2020 Examination Priorities

The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) published its 2020 Examination Priorities, an annual publication that enhances transparency and provides insights into...more

Foodman CPAs & Advisors

Who are you partnering with for your Financial Institution’s BSA/AML Independent Testing?

Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more

Stinson LLP

Missouri Financial Institutions Must Prepare for Impending Marijuana Banking Challenges

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In November 2018, Missouri voters passed Amendment 2, setting in motion state regulated medical marijuana. Over the last month, the Missouri Department of Health & Senior Services (DHSS) began approving license applications...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

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The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more

Sullivan & Worcester

FFIEC Examination Procedures for the Beneficial Ownership Rule

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The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more

Pillsbury Winthrop Shaw Pittman LLP

Beyond BSA Compliance: Human Trafficking Corporate Liability for Small Banks and MSBs

Smaller banks and money services businesses should expand their AML compliance to mitigate human trafficking corporate liability. Aside from the Bank Secrecy Act, federal law creates corporate liability for financial...more

Bass, Berry & Sims PLC

Anti-Money Laundering Update: FinCEN Makes Small Texas Bank Pay Big Fine for Violating Bank Secrecy Act

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This Post at a Glance: - FinCEN imposes $2 million penalty against community bank - Bank failed to conduct appropriate due diligence related to Mexican customer - Small banks, other financial institutions need to...more

K2 Integrity

Five Areas of Focus for the New CDD Rule

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While regulators haven’t yet spelled how the new customer due diligence (CDD) requirements for financial institutions will be implemented, banks, credit unions, securities firms, money services businesses, and casinos should...more

Baker Donelson

Common Trends in FINRA and SEC Regulatory Priorities

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Each year, both the Financial Industry Regulatory Authority (FINRA) and the United States Securities and Exchange Commission (SEC) issue guidance concerning their regulatory priorities for the coming year. This year, FINRA...more

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