Cryptocurrency: Wild West or Wall Street? [More with McGlinchey, Ep. 22]
On June 28, 2024, the Financial Crimes Enforcement Network released a notice of proposed rulemaking. The purpose of the proposed rule is to strengthen and modernize Anti-Money Laundering and Countering the Financing of...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
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
FinCEN’s recent preliminary rulemaking aims to enhance and modernize regulations with requirements and priorities that affect a broad range of “financial institutions” across industries—but lacks concrete guidance on...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
Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more
Immediately following the October 7 attack by Hamas on Israel, the United States Financial Crimes Enforcement Network (FinCEN) announced the creation of the Counter Terrorist Financing Taskforce— Israel (CTFTI)—a coalition 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
April 21, 2023- Assistant Secretary of the Treasury for Terrorist Financing and Financial Crimes Elizabeth Rosenberg and Deputy Homeland Security Adviser Joshua Geltzer hosted a roundtable at the U.S. Department of the...more
On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced in the U.S. Senate a new bipartisan bill, titled "Digital Asset Anti-Money Laundering Act of 2022" (the “Bill”), intended to curb the...more
On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert calling on financial institutions to be “vigilant” in guarding against attempts to evade the recent imposition of expanded Russia sanctions....more
On June 30, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first government-wide priorities (Priorities) for combatting money laundering and the financing of terrorism.1...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
The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more
On 18 December, the Financial Crimes Enforcement Network (FinCEN) at the U.S. Department of the Treasury announced highly anticipated and controversial new proposed requirements designed to mitigate illicit finance risks...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
On New Year’s Day 2021, Congress passed—over President Trump’s veto—a defense appropriations law containing the Anti-Money Laundering Act of 2020 (“AML Act”) and the Corporate Transparency Act, as part of a sweeping new set...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
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
On Monday, the Financial Crimes Enforcement Network (FinCEN) issued new Frequently Asked Questions (FAQs) regarding customer due diligence (CDD) requirements for covered financial institutions. The FAQs supplement FinCEN’s...more
First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more