BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
On June 20, 2024, Bill C-59, the Fall Economic Statement Implementation Act received royal assent. Division 8 of this legislation introduced various amendments to the Proceeds of Crime (Money Laundering) and Terrorist...more
On September 30, 2022, FinCEN published the Ultimate Beneficial Ownership (UBO) Reporting Rule (the Rule), which implements reporting requirements regarding Beneficial Ownership Information (BOI) under the Corporate...more
This article explores the application of retrieval-augmented generation combined with semantic search technologies in the detection of trade-based money laundering (TBML). Retrieval-augmented generation combined with semantic...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 concerns relating...more
The Financial Action Task Force (“FATF”) has re-rated the U.S. as “largely compliant” with FATF’s Recommendation 24, which pertains to transparency related to beneficial ownership of legal persons. Specifically, FATF...more
Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more
Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...more
ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a sweeping expansion of the Bank Secrecy Act’s (BSA) affirmative anti-money laundering (AML) and countering the financing 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 past few months have seen numerous high-profile enforcement actions highlighting an increasing trend, what Deputy Attorney General Lisa Monaco called “the biggest shift in corporate criminal enforcement that I’ve seen...more
Each year the amount of money laundered in the United States adds up to $300 billion, enough to build 158 Empire State Buildings. Criminals often use the washed cash to fund crypto hacking, terrorism – also known as...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
To more effectively counter transnational corruption and economic sanctions evasion, recent changes to the U.S. anti-money laundering (“AML”) whistleblower regime expand and reinforce whistleblower protections and rewards in...more
Substantial changes to Irish whistleblowing law will be introduced by the Protected Disclosures (Amendment) Act, 2022 (the “Amendment Act”) on 1 January 2023. Protection for whistleblowers is not a new concept in...more
The Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued final regulations to implement the reporting requirements under the federal Corporate Transparency Act (CTA). The CTA aims to further...more
The rising incidence of financial crime continues to haunt financial institutions globally. As per a recent industry report, more SARs (suspicious activity reports) were filed by ~80% of the firms in 2021. COVID-19 pandemic...more
On 1 August 2022, the Central Bank of the United Arab Emirates (the "CBUAE") issued "Guidance for Licensed Financial Institutions ("LFIs") on the risks relating to payments" (the "Guidance")....more
The U.S. Department of the Treasury (Treasury), on May 13, 2022, published its 2022 National Illicit Finance Strategy (the 2022 Strategy)—a comprehensive statement of the agency’s key priorities, goals, and plans for...more
On 7 January 2022, the European Commission adopted a delegated regulation (the “Regulation”) proposing revision of its EU AML List to add nine countries, including the Cayman Islands. The EU AML List is the EU’s list of...more
On March 11, 2022, a reform to the Mexican Banking Law (Ley de Instituciones de Crédito) was published in the Federal Official Gazette (Diario Oficial de la Federación) in order to provide a new procedure for the defense of...more
On February 4, the Department of the Treasury published a study on the facilitation of money laundering and terrorist financing through the art trade. Among other considerations, the report discussed the risks of financial...more
On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more
The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more
Join us for a round-table discussion moderated by Dr. Michele Malvesti with Juan Zarate, Chip Poncy, and Danny McGlynn, part of the team that spearheaded the post-9/11 counter-illicit finance regime. The group will share...more