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Risk Assessment Risk Management FinCEN

Paul Hastings LLP

Anti-Money Laundering Enforcement Risk Still Remains for Virtual Asset Services Providers

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Despite the Trump administration’s generally favorable stance toward cryptocurrency and blockchain innovation, virtual asset services providers (VASPs) must remain vigilant in complying with anti-money laundering (AML)...more

Oberheiden P.C.

10 Keys to Conducting an Effective AML/BSA Audit in 2025

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Financial institutions need to remain vigilant about managing anti-money laundering and Bank Secrecy Act (AML/BSA) compliance in 2025. As the financial ecosystem becomes increasingly complex, and as transactions increasingly...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Cadwalader, Wickersham & Taft LLP

Summer Regulatory Round-Up | July 2024

The banking regulators have not yet gone out on vacation, as demonstrated by this grab-bag of announcements, speeches, rules and guidance: Acting Comptroller of the Office of the Comptroller of the Currency (OCC),...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

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On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...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

Sheppard Mullin Richter & Hampton LLP

South Dakota Lenders on Tight Deadline for BSA/AML Compliance

On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

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Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

BakerHostetler

DSIR Deeper Dive: 2023 Crypto Threat Landscape

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Following one of the most turbulent years in crypto history, 2023, in contrast, unfolded as a year of reprieve, including from crypto threats. According to a July 12, 2023, report from blockchain analytics firm Chainalysis,...more

K2 Integrity

U.S. Authorities Amplify Enforcement Efforts to Address Financial Crime Risks in the Digital Asset Industry

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The United States Department of the Treasury has continued to signal that it will focus policy, regulatory, and enforcement attention on the financial crime and sanctions risk in the crypto and digital asset ecosystem...more

Goodwin

FinCEN Warns Against Evasion of Russian Sanctions

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In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more

White and Williams LLP

NYDFS Announces Cyber Insurance Risk Framework to Address Increasing Cyber Risk

Even if your company does not report to the New York Department of Financial Services (DFS), all insurers should heed warning to prepare for future cyber risk regulations and requirements. Cyber risk is real and has the...more

Moore & Van Allen PLLC

Human Trafficking Awareness – What Financial Institutions Need to Know

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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

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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

K2 Integrity

China Emerging as an Increasing Driver of Global Illicit Finance Risk

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Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more

Ballard Spahr LLP

Congress Proposes National Directory of Beneficial Owners of Legal Entities

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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

K2 Integrity

FinCEN’s Beneficial Ownership Rule and Increased AML Burden

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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

K2 Integrity

Upping the Ante on Casinos’ AML Compliance

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FinCEN focus requires major shift in gaming business practices - Which complex, global industry where billions of dollars exchange hands every day, and where high-net-worth customers park significant sums, is facing...more

The Volkov Law Group

The Banking Stepchild: Money Service Businesses

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Sometimes risk analysis can result in paralysis. Finding your risk tolerance and applying it to specific situations requires a nuanced approach. I am always wary of anyone who tells me categorical rules – e.g. we do not...more

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