There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more
On the one hand, the year ended where it began. The legislation on stabelecoins and market structure that would provide a regulatory framework for digital assets has still not been enacted into law. And Securities and...more
El 20/10/23, FinCEN emitió Señales de Alerta (“Red Flags”) sobre el Financiamiento del Terrorismo para ayudar a las instituciones financieras a identificar flujos de financiamiento para la organización terrorista Hamás en...more
On 10/20/23, Terrorist Financing Red Flags were issued by FinCEN to assist financial institutions in identifying funding streams for the terrorist organization Hamas in response to Hamas’s terrorist attack on the people of...more
Convertible virtual currency (CVC) mixing is in the crosshairs of U.S. national security policy. On October 19, 2023, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”)...more
On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its first “Gap Rule” enforcement action in a Consent Order with Bancrédito International Bank and Trust...more
The market for digital assets has exploded in recent years. Digital and virtual currency activities provide great opportunities financially and technologically. However, such currencies can be utilized for illicit activity...more
On August 16, 2022, the United States Court of Appeals for the D.C. Circuit issued its ruling in Estate of Jeremy Isadore Levine, et al. v. Wells Fargo Bank, N.A., No. 21-7036, –F.4th– (D.C. Circuit August 16, 2022), a case...more
As we blogged yesterday, OFAC has been busy. Right before OFAC designated the virtual currency exchange SUEX for allegedly facilitating ransomware payments, OFAC announced another significant but more traditional action on...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
This quarter saw the announcement of sweeping new sanctions against Russia’s billionaire class and their corporate holdings, and included the Trump Administration’s first issuance of sanctions against Russia for meddling in...more
President Trump signs the “Countering America’s Adversaries Through Sanctions Act,” which — among other measures — requires Congressional review to ease Russia-related sanctions. On Wednesday, August 2, 2017, President...more
On March 24, 2017, the U.S. Department of Justice unsealed an indictment charging Kassim Tajideen, an alleged prominent financial supporter of the Hizballah terror organization, with evading U.S. sanctions and conspiring to...more
The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more
Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more
With the Panama Papers scandal and government promises of continued aggressive AML enforcement, financial institutions face a variety of risks that require increased vigilance and mitigation strategies....more
Why it matters - Swiss-based UBS AG's agreement to pay more than $1.7 million to the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) underscores the scope of OFAC sanctions and the complications...more
On September 22, 2014, a Brooklyn jury found Arab Bank, Jordan’s largest lender, guilty of violating the U.S. Anti-Terrorism Act for providing financial services to individuals and entities linked to Hamas. Hamas is currently...more
On August 10, 2012, the United States delivered its latest economic blow to Iran by enacting the Iran Threat Reduction and Syria Human Rights Act of 2012. U.S. companies have long been forbidden from engaging in most...more