Recent Developments in Anti-Money Laundering - The Consumer Finance Podcast
Investment Management Update – Exit Strategies
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more
On February 7, 2023, the Securities and Exchange Commission’s (SEC) Division of Examinations (EXAMs) announced its 2023 Examination Priorities (the “Priorities”), which highlight areas it expects to target in 2023...more
New York’s Department of Financial Services (“DFS”) recently announced a $100 million settlement with Coinbase, Inc., one of the world’s largest cryptocurrency exchanges, for Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”)...more
The Financial Crimes Enforcement Network’s most recent financial trend analysis report on ransomware-related Bank Secrecy Act filings for 2021 reveals an increased number of ransomware attacks and that a substantial number of...more
In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more
In a few short weeks, the global loss attributable to cybercrime is expected to surpass $6 trillion.* Therefore, in an effort to protect financial institutions and consumers from further loss, agencies including the United...more
On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more
On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more
The decision to pay millions to a cyber criminal has never been easy, but it is now even more complex. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) issued an updated advisory on September 21,...more
On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) provided an update on implementation of the Anti-Money Laundering Act of 2020 (AML Act) and issued the first government-wide priorities for anti-money...more
The legislation updates the Children’s Online Privacy Protection Act (COPPA) by prohibiting internet companies from collecting personal information from anyone 13- to 15-years old without the user’s consent Senators...more
The U.S. Securities and Exchange Commission (SEC) and Financial Industry Regulatory Authority (FINRA) have each published their annual examination priorities for 2021, signaling areas of scrutiny that broker-dealers should...more
Providing yet more proof that anything positive can be twisted into something negative, the Financial Crimes Enforcement Network (“FinCEN”) released a Notice yesterday “to alert financial institutions about the potential for...more
On December 17, 2020, the Office of the Comptroller of the Currency, Treasury (OCC); the Federal Reserve; and the Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking that would require...more
In this Issue. The Federal Deposit Insurance Corporation (FDIC) was busy this week, finalizing rules that modernize brokered deposits regulations, establish new standards for parent companies of industrial loan companies and...more
The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more
October is National Cybersecurity Awareness Month, and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) kicked off the month by issuing two...more
On October 1, 2020, the United States Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to companies that pay a ransom in the wake of a cyberattack. Specifically, the advisory warned that...more
In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more
Today we are very pleased to welcome guest blogger Moyara Ruehsen, PhD, CAMS, CFCS, who is an Associate Professor and Director of the Financial Crime Management Program at the Middlebury Institute of International Studies in...more
As we previously discussed, FINRA issued guidance to member firms and their associated persons in April 2020 to remain “vigilant in their surveillance against cyber threats and take steps to reduce the risk of cyber events.”...more
The Exam Priorities of the SEC’s Office of Inspections and Compliance or OCIE, announced on January 7, 2020 (the “Exam Priorities”), should be a key area of focus for every investment advisor and investment company. The Exam...more
The Financial Industry Regulatory Authority published its 2019 Report on Examination Findings and Observations (2019 Report) on October 16, 2019. This marks the third annual report of FINRA findings, but in a departure from...more
FinCEN Director Kenneth A. Blanco delivered prepared remarks on September 24 at the 2019 Federal Identity (FedID) Forum and Exposition in Tampa, Florida. Director Blanco summarized the topics of his remarks by stating the...more
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has announced new efforts to crack down on Business Email Compromise (BEC) schemes and those who profit from such scams. BEC fraud schemes generally...more