Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors -
On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more
9/4/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Customer Due Diligence (CDD) ,
FATF ,
Financial Institutions ,
FinCEN ,
Joint Statements ,
Politically Exposed Person (PEPs) ,
Risk-Based Approaches
On August 6, the U.S. Court of Appeals for the District of Columbia kept in place $50,000-per-day fines on three Chinese banks—whose identities are redacted—for refusing to comply with subpoenas issued by the Department of...more
8/9/2019
/ Anti-Money Laundering ,
Appeals ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
Financial Records ,
Financial Transactions ,
Foreign Banks ,
Money Laundering ,
National Security ,
North Korea ,
Patriot Act ,
Subpoenas
Critics Bemoan Removal of Potential Weapon Against Shell Companies -
Last week, and on the eve of a scheduled markup of the original bill in the House Financial Services Committee, a new draft of the Counter Terrorism and...more
6/21/2018
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Customer Due Diligence (CDD) ,
Deregulation ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Proposed Legislation ,
Reporting Requirements ,
Transparency
We previously have observed that financial institutions face an increasing risk that alleged Anti-Money Laundering (“AML”) and Counter-Terrorism Financing (“CTF”) violations will lead to follow-on allegations of securities...more
On June 5, the SEC filed suit against Salt Lake City-based Alpine Securities, Corp. (“Alpine”). The complaint, filed in the Southern District of New York, alleges that the broker-dealer ran afoul of AML rules by “routinely...more
The Supreme Court granted certiorari on April 3 to decide whether Jordan-based Arab Bank may be liable for claims including allegations that its New York branch processed transactions for known terrorists. While the central...more
Banks stand to advance the fight against human trafficking and modern slavery by reporting suspicious transactions and other financial activity that raise red flags, according to a report on March 15, 2017. Published by the...more
The Philippines has been identified by the U.S. as a “major money-laundering country” in the 2017 International Narcotics Control Strategy Report (“Report”), published this month. The country now joins 87 others as one “whose...more
Despite the staggering $8 billion figure estimated to be spent on global compliance in 2017, U.S.-based rules regarding Anti-Money Laundering (“AML”) and Combating the Financing of Terrorism (“CFT”) remain anchored in their...more
2/22/2017
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
Blockchain ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Financial Institutions ,
Money Laundering ,
Technology ,
Terrorism Funding ,
Terrorist Financing ,
Terrorist Financing Regulations ,
Virtual Currency
In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more
2/7/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
Bitcoin ,
BSA/AML ,
Civil Forfeiture ,
Currency Transaction Reports (CTR) ,
Digital Currency ,
Financial Institutions ,
Forfeiture ,
Money Laundering ,
Virtual Currency
Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more
2/7/2017
/ Bitcoin ,
Department of Justice (DOJ) ,
Digital Currency ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
Internal Revenue Code (IRC) ,
IRS ,
John Doe Investigation ,
Money Laundering ,
Summons ,
Swiss Banks ,
Tax Evasion ,
Technology ,
Virtual Currency
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
2/3/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Casinos ,
Consumer Lenders ,
Customer Due Diligence (CDD) ,
FATF ,
Financial Institutions ,
FinCEN ,
Fines ,
Gambling ,
Gaming ,
Geographic Targeting Order ,
Money Laundering ,
Mortgage Lenders ,
Mortgages ,
NYDFS ,
Offshore Funds ,
Panama Papers ,
Popular ,
Real Estate Market ,
Suspicious Activity Reports (SARs) ,
Tax Evasion