News & Analysis as of

Suspicious Activity Reports (SARs) Regulatory Oversight

Troutman Pepper Locke

Federal Banking Agencies Issue RFI on Payments and Check Fraud Mitigation Strategies

Troutman Pepper Locke on

On June 16, the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board, and the Office of the Comptroller of the Currency (OCC) issued a joint request for public comment on potential ways to address payments...more

White & Case LLP

“Unsubstantiated” suspicious transaction reports

White & Case LLP on

While financial institutions, on the one hand, are in the process of implementing and preparing to apply the fundamental amendments and changes that will take place in upcoming years by the EU AML Package—entering into force...more

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

Skadden, Arps, Slate, Meagher & Flom LLP

UK Government Expands Enforcement Measures To Address Fraud and Money Laundering

On 22 September 2022, the U.K. government introduced the Economic Crime and Corporate Transparency Act 2022. The new bill is currently navigating its way through the U.K. Parliament and is likely to receive royal assent in...more

Orrick, Herrington & Sutcliffe LLP

The CFTC Begins Policing AML Enforcement

Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town.  The Commodity Futures Trading Commission recently finished its fiscal year with...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Ballard Spahr LLP

Guilty Pleas Highlight Illicit Funneling of Chinese Cash to Casinos

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Government Suggests that Unusual Pleas are Just the Tip of an Iceberg - Chinese law generally prohibits its citizens from converting more than $50,000 in Chinese yuan into foreign currency in a year.  On Monday, two men...more

Stinson LLP

Missouri Financial Institutions Must Prepare for Impending Marijuana Banking Challenges

Stinson LLP on

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

Carlton Fields

Are Bank Regulators "Mellowing Out" on Cannabis?

Carlton Fields on

Federal bank regulators no longer require banks to submit suspicious activity reports (SARs) for legally authorized hemp business transactions, absent another required circumstance....more

Ballard Spahr LLP

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

Ballard Spahr LLP on

On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

Lowndes

Long-Awaited Guidance for Banking Hemp Clients Released

Lowndes on

Since the effective date of the 2018 Farm Bill, banking and the inability to acquire financing have been major impediments for the hemp industry. While demand for hemp continues to grow, banking regulations have still been...more

Orrick - On the Chain

In Case You Needed A Reminder – AML/CFT Regulations Apply to Transactions in Cryptocurrencies

Orrick - On the Chain on

Earlier this month, the leaders of the U.S. Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, and the U.S. Securities and Exchange Commission released a joint statement reminding individuals...more

Ballard Spahr LLP

FinCEN Director Addresses Virtual Currency and Touts Regulatory Leadership and Value of SAR Filings

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Address Emphasizes Role of SARs in Fighting Illegal Activity, Including Drug Dealing Fueling the Opioid Crisis - Kenneth Blanco, the Director of the Financial Crimes Enforcement Network (“FinCEN”), discussed last week...more

Ballard Spahr LLP

The U.S. Casino and Gaming Industry: AML/BSA Regulation and Enforcement

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As we blogged yesterday, British Columbia’s (“B.C.”) Attorney General David Eby recently released an independent and very detailed report examining money laundering in B.C.’s gaming industry and providing 48 recommendations...more

The Volkov Law Group

The Need for Anti-Money Laundering Regulatory Reform

The Volkov Law Group 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

Ballard Spahr LLP

FinCEN Fines Texas Bank $2M for Alleged Failure to Vet and Monitor Mexican Correspondent Banking Relationship – But Touts Bank’s...

Ballard Spahr LLP on

FinCEN recentlty announced entry of a $2 million assessment against Lone Star National Bank, a private bank operating out of Texas, for the bank’s allegedly willful violations of the Bank Secrecy Act (“BSA”) and inadequate...more

Ballard Spahr LLP

Money Laundering Watchdog Criticizes Lax AML Enforcement and “Creative Compliance” in Wake of Panama Papers

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PANA Issues Recommendations to European Parliament: Tougher Enforcement, Greater Transparency, Improved Information Sharing and Prohibitions Against Outsourcing of Customer Due Diligence....more

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