News & Analysis as of

Suspicious Activity Reports (SARs)

FINCEN Advises That Participation in a Foreign Tax Regularization Program By Itself Does Not Trigger SAR Filing Obligation

by Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FinCEN”) recently advised that a financial institution is not required to file a Suspicious Activity Report (“SAR”) based solely upon a customer’s inquiry into or participation in a...more

FinCEN: No SAR Filing Obligation When Customers Voluntarily Disclose to Home Country

by Jones Day on

On February 21, 2018, the Financial Crimes Enforcement Network ("FinCEN") issued highly anticipated guidance affecting reporting obligations for U.S. financial institutions in response to an inquiry by the Florida...more

Bank Agrees to $613 Million Settlement Over Failings of Anti-Money Laundering Program

by Weiner Brodsky Kider PC on

On February 15, 2018, a national bank agreed to pay $613 million because of its failure to implement an effective anti-money laundering program, and because of its failure to report suspicious transactions....more

New Legislation Introduced in 2017 Signals the Beginning of a Strong Push for AML Reform

There is universal acknowledgement that anti-money laundering (“AML”) monitoring has become progressively costlier (both in terms of time and money) since the Bank Secrecy Act (“BSA”) was passed nearly five decades ago, and...more

Bridging the Week - February 2018 #3

The United States Supreme Court made clear that, to take advantage of a key anti-retaliation protection of the Dodd-Frank Wall Street Reform and Consumer Protection Act, an employee whistleblower must identify potential...more

DOJ ‘Reminds’ Banking Industry of the Significant Risks Created by an Inadequate BSA/AML Program

Last week the Department of Justice (DOJ) announced criminal charges against U.S. Bancorp “consisting of two felony violations of the Bank Secrecy Act (‘BSA’) by its subsidiary, U.S. Bank National Association (the ‘Bank’),...more

US Bancorp Pays $613 Million And Joins The Ranks Of AML Violators

by Michael Volkov on

Prosecutors and regulators are targeting global banks.  The beginning of 2018 has seen dominated by enforcement actions of financial institutions – the Federal Reserve’s unprecedented enforcement action against Wells Fargo;...more

Rabobank Coughs Up $368 Million and Pleads Guilty to Conspiracy to Money Launder and Obstruct Investigation

by Michael Volkov on

The Justice Department announced a guilty plea by a subsidiary of Rabobank, a Dutch global bank, to a conspiracy to violate money laundering laws and obstruct a regulatory investigation of Rabobank’s activities in California....more

Cryptocurrency and Money Laundering

by Sanford Millar on

In a recent enforcement action FinCEN, the Financial Crimes Enforcement Network levied an $8 million fine on a California card club for violation of the Anti-Money Laundering provisions of the Bank Secrecy Act. (“BSA”). One...more

U.S. Subsidiary Of Dutch Bank Pleads Guilty To Allegations That It Conspired To Obstruct OCC Examination Of AML Program

by Shearman & Sterling LLP on

On February 7, 2018, Dutch bank Rabobank’s U.S. subsidiary pleaded guilty to conspiring to impair, impede, and obstruct a review by the Office of the Comptroller of the Currency (“OCC”) of the bank’s anti-money laundering...more

SEC’s OCIE Announces National Exam Program Priorities

by Dorsey & Whitney LLP on

The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) published its National Exam Program Examination Priorities. This year’s publication comes in the form of a brochure, much like the one issued by the...more

SEC Targets AML as Exam Priority

by Ballard Spahr LLP on

Wednesday, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2018 examination priorities, released in order to “improve compliance, prevent fraud, monitor risk, and inform policy.” ...more

The Making of a Super-SAR: A Case Study

by White & Case LLP on

The UK Government has continued to develop the UK's existing anti-money laundering ("AML") framework, both in response to EU driven initiatives, but also as part of its own national strategy. The Criminal Finances Act 20171...more

Congress Contemplates Broad AML/BSA Reform

by Ballard Spahr LLP on

As we blogged earlier this week, Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), in committee in the Senate.  The CTIFA proposes the most substantial overhaul to the Bank...more

Congress Proposes National Directory of Beneficial Owners of Legal Entities

by 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

FINRA’s 2018 Regulatory and Examination Priorities: New Focus on Cryptocurrencies and Initial Coin Offerings

by Bryan Cave on

As in the past, the Financial Industry Regulatory Authority (“FINRA”) marked the beginning of the new year with the release of its 2018 Regulatory and Examination Priorities Letter (the “Letter”). Similar to prior letters,...more

NY Fines Money Transfer Company $60M for Lax Controls, Facilitating Suspicious Transaction

by Weiner Brodsky Kider PC on

The New York State Department of Financial Services fined a large money transfer company $60 million for allowing some of its agents to aid in a significant number of money laundering transactions—including payments that...more

The Need for Anti-Money Laundering Regulatory Reform

by Michael Volkov on

It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious. Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML...more

AML Regulation and Compliance Trends

by Michael Volkov on

Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more

Regulators Slap Banks, MSBs and Card Club with AML Violation Penalties

by Michael Volkov on

Financial institutions face enormous pressures with respect to anti-money laundering compliance. These burdens are about to grow with implementation of customer due diligence rules. In 2017, federal and state regulators...more

Beware What You Share: Privilege Waiver Risks in Investigations

by McGuireWoods LLP on

In responding to regulatory and government investigations, firms are often faced with the question of how to balance the desire to cooperate with the need to preserve privilege over an internal investigation. Financial...more

Mexico’s AML Regime Evaluated by the FATF: Systemic Improvement, but Suspicious Transaction Reporting and Law Enforcement Efforts...

by Ballard Spahr LLP on

Last week, the Financial Action Task Force (“FATF”) issued a report concluding that Mexico needs to “step up efforts in pursuing money launderers.” ...more

Marijuana Enforcement: DOJ Cole Memo Up in Smoke

by Ballard Spahr LLP on

Attorney General Sessions Announces Rescission of Obama Administration Policies on Marijuana Enforcement; Financial Institutions Lose Grounds to Permit Financial Transactions with Marijuana Businesses....more

Federal Data Shows More Banks Are Serving Marijuana Businesses

by Fox Rothschild LLP on

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has released updated statistics showing a steady increase in the number of depository institutions that actively bank U.S. marijuana businesses. As of...more

Will Bankers = Law Enforcers on 5/11/18?

by Foodman CPAs & Advisors on

On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018. The CDD Rule applies to Covered Financial Institutions (federally...more

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