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
As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...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
Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more
In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...more
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
Decentralized Finance (DeFi) is an umbrella term used to describe financial services provided outside of the traditional markets, that rely on blockchain technologies to create innovative products instead of relying on...more
Cryptocurrency, with its anonymity and decentralization, has revolutionized financial transactions. However, it has also opened doors for illicit activities, such as terrorist financing. Below we explore the role of...more
The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more
The U.K. Joint Money Laundering Steering Group opened a consultation on July 28, 2023 on guidance on the U.K. travel rule for cryptoasset transfers. The Money Laundering and Terrorist Financing (Amendment) (No. 2) Regulations...more
Non-bank mortgage lending entities would become subject to the anti-money laundering and anti-terrorist financing (AML/ATF) obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (the PCMLTFA)...more
On February 14, the Conference of State Bank Supervisors commented that FinCEN should be more explicit in its inclusion of state regulators as agencies that can request access to FinCEN’s forthcoming secure, non-public...more
On January 12, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) issued Counter Terrorism General License (GL) 21B, “Authorizing Limited Safety and Environmental Transactions Involving Certain...more
On January 5, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced sanctions pursuant to Executive Order 13224 against a key financial facilitation network of the Islamic State of Iraq and Syria...more
The Cayman Islands recently introduced measures to further improve its technical compliance with the 40 Financial Action Task Force (“FATF”) recommendations relating to anti-money laundering and countering the financing of...more
In this post we discuss disclosure obligations under Canadian economic sanctions and anti-terrorism laws, including in respect of financial services providers. As discussed below: There are disclosure obligations...more
At the end of March 2022, the Israeli Ministry of Justice published a draft amendment to the Prohibition on Money Laundering Law. The proposed amendment seeks to grant supervisory authority to the Israel Money Laundering and...more
On February 21, 2022, Commission Delegated Regulation was published in the Official Journal of the European Union which will add the Cayman Islands to the list of countries that have been identified by the European Commission...more
There are various exciting regulatory developments that we expect to see in Hong Kong throughout 2021. This bulletin looks at a number of key regulatory areas of focus in relation to: i) anti-money laundering and...more
Future of UK financial services: Treasury Committee inquiry written evidence - The House of Commons Treasury Committee has published written evidence to the committee's inquiry into the future of financial services in the...more
European Union Withdrawal (Consequential Modifications) (EU Exit) Regulations 2020 - The European Union Withdrawal (Consequential Modifications) (EU Exit) Regulations 2020 (SI 2020/1447) have been published, together with...more
A Director of Enforcement at the Financial Conduct Authority (FCA) has set out some of the key challenges the regulator expects in its new role as AML/CTF (anti-money laundering/counter terrorist financing) supervisor for...more
In Hong Kong, any person operating a money service is required to obtain a Money Service Operator (MSO) licence. Money services include the following...more
The Luxembourg government and the CSSF recently have taken a number of measures to combat money laundering and terrorist financing. In other developments: the current Luxembourg Brexit laws will be rendered inapplicable by...more