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Risk Assessment BSA/AML Suspicious Activity Reports (SARs)

Troutman Pepper Locke

Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast

Troutman Pepper Locke on

In this episode of Payments Pros, host Carlin McCrory discusses a recent consent order between Patriot Bank and the Office of the Comptroller of the Currency (OCC) following a $27 million loss. The order addresses unsafe...more

Morrison & Foerster LLP

FinCEN Expands its Reach with Final Rules for Investment Advisers and the Residential Real Estate Sector

Key Takeaways - •FinCEN has issued two new final rules to significantly expand regulation around certain investment adviser and residential real estate sectors to combat illicit finance in these areas. These highly...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

Ballard Spahr LLP on

Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

Ballard Spahr LLP on

On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Ballard Spahr LLP

Bank’s Digital Assets Business Strategy Draws Federal Reserve Scrutiny

Ballard Spahr LLP on

The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more

Ballard Spahr LLP

BSA Filings and Their Utility to Law Enforcement:  An Industry Viewpoint

Ballard Spahr LLP on

In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

Ballard Spahr LLP on

On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Ballard Spahr LLP

South Dakota Regulator Requires BSA/AML Compliance for Money Lender Licensees and Non-Residential Mortgage Lenders

Ballard Spahr LLP on

The South Dakota Division of Banking issued a Memorandum notifying all licensed money lenders and non-residential mortgage lenders of their Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) obligations under a 2020 Final...more

WilmerHale

2021 AML Trends and Developments

WilmerHale on

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

White & Case LLP

FinCEN Invites Comments on Anti-Money Laundering Program Effectiveness

White & Case LLP on

On September 16, the US Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) seeking to update the US anti-money laundering (AML) regime. This is an historic opportunity for...more

Ballard Spahr LLP

Regulatory Round Up: FinCEN Wants To Know What You Think About Modernizing the BSA/AML Regime

Ballard Spahr LLP on

Second Post in a Three-Post Series Regarding Recent Regulatory Action by FinCEN - On September 16, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advance Notice of Proposed Rulemaking (“ANPRM”)...more

Eversheds Sutherland (US) LLP

The OCC’s 2019 annual report addresses anti-money laundering risks for financial institutions

The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more

Moore & Van Allen PLLC

Human Trafficking Awareness – What Financial Institutions Need to Know

Moore & Van Allen PLLC on

Anti-Money Laundering and Know Your Customer departments at financial institutions are on the front lines of human trafficking. Not only does enhanced transaction monitoring help law enforcement identify trafficking...more

Ballard Spahr LLP

AMA Updates AML Best Practices for AML Compliance

Ballard Spahr LLP on

AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more

Ballard Spahr LLP

Update: Government Enforcement in the Cryptocurrency Space

Ballard Spahr LLP on

First Post in a Two-Part Series - Recent actions in the crypto realm demonstrate that authorities and regulators have not slackened their commitment to applying and enforcing Anti-Money Laundering (“AML”) laws and...more

The Volkov Law Group

AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions

The Volkov Law Group on

Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations.  With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more

Ballard Spahr LLP

Congress Proposes National Directory of Beneficial Owners of Legal Entities

Ballard Spahr LLP on

Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), currently in committee in the Senate.  The CTIFA proposes the most substantial overhaul to the Bank Secrecy Act (“BSA”) since...more

King & Spalding

FinCEN Issues Final Rule on Customer Due Diligence Requirements for Legal Entity Customers

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On May 11, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) published its Final Rule (Rule) requiring covered financial institutions, including, banks, brokerdealers, mutual funds, and money...more

The Volkov Law Group

The 5 Most Common AML Compliance Program Deficiencies

The Volkov Law Group on

Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance...more

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