Cryptocurrency: Wild West or Wall Street? [More with McGlinchey, Ep. 22]
On August 1, 2024, the Department of Justice launched its Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). Under this 3-year initiative managed by DOJ’s Criminal Division, a whistleblower may be eligible...more
In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more
The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...more
On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more
On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more
Today we are very pleased to welcome, once again, guest blogger Dr. Kateryna Boguslavska of the Basel Institute on Governance (“Basel Institute”), who will discuss the Basel Institute’s release of the 12th annual Public...more
The Financial Action Task Force (“FATF”) recently released its Report on the State of Effectiveness and Compliance with the FATF Standards (“Report”). The Report contains the results of its 4th Round of Mutual Evaluations...more
As we reported in April, the Anti-Money Laundering Act of 2020 (AMLA 2020) aims to strengthen protections against money laundering, terrorism financing, and other illegal activities through a variety of mechanisms, including...more
On June 30, 2021, FinCEN announced the first set of government-wide AML/CFT Priorities, as required by the Anti-Money Laundering Act of 2020 ("AML Act"). Consistent with the National Strategy for Combating Terrorist and Other...more
La sección 6307 del Acto (“AML ACT of 2020”) requiere la capacitación anual para Examinadores sobre la lucha contra el lavado de dinero y el financiamiento del terrorismo. La capacitación debe realizarse en consulta con...more
The U.S. Anti-Money Laundering Act of 2020 (AML Act) became law on January 1 when the United States Congress passed the broader National Defense Authorization Act for 2021 over a presidential veto. Although it is a U.S. law,...more
On January 1, 2021, Congress enacted a broad range of anti-money laundering (“AML”) reforms within the Anti-Money Laundering Act of 2020 (the “AML Act”), as part of the National Defense Authorization Act for Fiscal Year 2021...more
Section 314(b) of the USA PATRIOT Act (Sec 314) was drafted by Congress in 2001 to allow financial institutions to work with law enforcement agencies and with each other to support the common goal of deterring money...more
As part of a modernization of the nation’s anti-money laundering regime, the Anti-Money Laundering Act of 2020 creates enhanced whistleblower rewards that are likely to lead to increased enforcement action....more
Beginning on October 21, 2020, the Financial Action Task Force (“FATF”) held its three-day Plenary meeting virtually. It was the first Plenary of Germany’s two-year Presidency. As part of the Plenary outcomes, the FATF...more
(i) a licensing regime for virtual asset trading platforms in Hong Kong, including anti-money laundering obligations; (ii) a two-tier registration regime for dealers in precious metals and stones; and...more
Section 314 of the USA PATRIOT Act (Sec 314) was drafted by Congress in 2001 to allow financial institutions to work with law enforcement agencies and with each other to support the common goal of deterring money laundering...more
GAFILAT (Grupo de Acción Financiera de América Latina) publicó una Segunda Actualización del Informe Regional de Amenazas de Lavado de Dinero (2017-2018) que incluye: ANEXO VI: AMENAZAS RELACIONADAS CON LA PANDEMIA COVID-19....more
GAFILAT (Financial Action Task Force of Latin America) published a Second Update to the Money Laundering Regional Threat Report (2017-2018) that includes: ANNEX VI: THREATS RELATED TO THE COVID-19 PANDEMIC. ...more
For those who haven’t yet had the time to catch up on the ongoing #FinCENFiles reporting, the following is a brief description of the underlying story and some thoughts about the eventual effects on the parties involved. ...more
Beneficial ownership is a topic which presents significant challenges to compliance officers charged with untangling a web of ownership interests that span numerous international jurisdictions and ownership structures. ...more
Second Post in a Two-Post Series on Recent FATF Activity - As we just blogged, the Financial Action Task Force (“FATF”) issued a statement from its President on COVID-19 and measures to combat illicit financing during the...more
First Post in a Two-Post Series on Recent FATF Activity - Members presumably working from home, the Financial Action Task Force (“FATF”) was active last week, first issuing its 3rd Enhanced Follow-up Report & Technical...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