The world of business intelligence and corporate investigations has not been left untouched by the unstoppable march of technological innovation. Today’s investigations benefit greatly from technology-driven solutions to the...more
The release of the Pandora Papers, a leak of approximately 12 million documents, exposed how foreign leaders and private actors use tax havens to conceal their wealth, with the United States a destination of choice. For...more
Los cambios a la Ley de Secreto Bancario bajo la Ley de Autorización de Defensa Nacional (“NDAA – “National Defense Authorization Act”) contienen requisitos para que las entidades legales cubiertas informen sobre sus...more
Changes to the Bank Secrecy Act incorporated into the National Defense Authorization Act (NDAA) contain requirements for beneficial ownership disclosure by covered legal entities at the time of their creation for inclusion in...more
The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/CFT threats. ...more
There is a Bill (H.R. 6068), originally drafted on November 14, 2017, called the Counter Terrorism and Illicit Finance Act (CTIFA). The Bill intended to propose a substantial overhaul to the Bank Secrecy Act (BSA). ...more
The beleaguered law firm at the center of the international Panama Papers scandal – Mossack Fonseca – has announced that it is closing its doors. It offered no apologies....more
The British Virgin Islands (“BVI”) is a small chain of islands in the Caribbean situated between Puerto Rico and St. Maarten. The BVI has been a top sailing destination since the days of Sir Francis Drake. The BVI is a...more
Central Bank launches ORION II platform to authorise all QIAIFs applications - All QIAIFs applications (including ICAVs) will be processed via the CBI’s ORION platform allowing consistency with other legal structures and...more
Sometimes it takes a scandal to advance a policy or law enforcement cause. The Panama Papers scandal has given new life to financial regulators around the world who seek to impose customer due diligence requirements on banks...more
In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more
On May 10, 2016, the Treasury Department issued proposed regulations that, if approved, will require business entities formed in the United States that are owned by a single foreign person to obtain an employer identification...more
In a news conference May 6, President Obama addressed recently announced rules and proposed regulations intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more
On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued the final version of its long-awaited “Customer Due Diligence Rules” under the Bank Secrecy Act. The final rules impose a new requirement on...more
The idea that a “fifth pillar” of Anti-Money Laundering (“AML”) compliance – customer due diligence requiring U.S. banks, broker-dealers, mutual funds, commodity futures merchants, and introducing brokers (“covered financial...more
When a scandal hits the media like the Panama Papers leak of 11.5 million confidential legal records, we all know what to expect. Criminal investigations, regulatory responses, and of course, congressional hearings of some...more
In a recent news conference President Obama addressed rules and proposed regulations announced Thursday intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more