The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more
10/9/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Whistleblowers
In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more
7/21/2023
/ Administrative Law Judge (ALJ) ,
Anti-Money Laundering ,
Banking Examinations ,
BSA/AML ,
Employee Misconduct ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Money Laundering ,
OCC ,
Popular ,
Rabobank ,
White Collar Crimes
The New York State Department of Financial Services (“NYDFS” or “the Department”) published a press release on February 24, 2022 announcing the issuance of a Consent Order (“the Consent Order”) to the National Bank of...more
On December 1, 2021, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the “Manual”), which provides guidance to...more
First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more
Is Art an “Ideal Playing Ground” for Money Laundering?
Last week, the Permanent Subcommittee on Investigations for the U.S. Senate released a detailed, 147-page report titled “The Art Industry and U.S. Policies That...more
8/6/2020
/ AMLD V ,
Anti-Money Laundering ,
Art Auctions ,
Art Dealers ,
Art Sales ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Due Diligence ,
EU ,
Financial Institutions ,
Financial Regulatory Reform ,
Fine Art ,
Paintings Sculptures and Engravings ,
Proposed Legislation ,
Suspicious Activity Reports (SARs)