We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more
7/25/2025
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Regulatory Agencies ,
Regulatory Reform ,
Regulatory Requirements ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
A Gesture Providing Limited Solace to a Now-Defunct Bank -
Six years ago, in early 2018, we blogged about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (“FinCEN’s”) designation of ABLV Bank, AS...more
The Federal Reserve Bank of Philadelphia (the “Philly Fed”) recently executed an agreement (the “Agreement”) with Pennsylvania-based Customers Bank (and its Customers Bancorp, Inc. holding entity) (collectively, “Customers”)....more
8/16/2024
/ Anti-Money Laundering ,
Banks ,
BSA/AML ,
Digital Assets ,
Financial Institutions ,
Financial Services Industry ,
FRB ,
IRS ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Suspicious Activity Reports (SARs)
In United States v. An, et al., 22-cr-640 (KAM) (E.D.N.Y. May 7, 2024), the Eastern District of New York recently addressed and rejected an argument by defendants that Ciminelli v. United States required dismissal of money...more
We previously have blogged on actions taken by the DOJ’s “Task Force KleptoCapture,” an interagency law enforcement task force with a mandate to target sanctioned Russian and pro-Russian oligarchs. While explicitly launched...more
3/1/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Banks ,
Criminal Fascilitation ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Services Industry ,
International Emergency Economic Powers Act (IEEPA) ,
Military Conflict ,
National Security ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Sanction Violations ,
Ukraine
Priorities Echo Prior Alerts and Enforcement Actions -
The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more
10/20/2023
/ Alternative Trading System (ATS) ,
AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Due Diligence ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
SEC Examination Priorities ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
We previously blogged on an advisory issued by FinCEN alerting financial institutions to the various financial mechanisms used by traffickers of fentanyl and synthetic opioids to launder the burgeoning proceeds of their...more
Judge Jed Rakoff of the Southern District of New York issued an opinion last week on a motion to dismiss in a putative class action securities fraud case against Deutsche Bank (“DB”) and several current and former bank...more
Acting Director Suggests that Financial Institutions Should “Welcome” the Program -
Himamauli Das, the Acting Director of the Financial Crimes Enforcement Network (“FinCEN”), spoke about the Anti-Money Laundering Act of...more
We blogged previously on the significant steps the European Union (“EU”) recently has taken toward implementing a rigorous new transnational anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”)...more
We previously blogged about the Financial Crimes Enforcement Network’s (“FinCEN’s”) issuance on June 30 of the first government-wide list of priorities for anti-money laundering and countering the financing of terrorism...more
European Commission Proposes EU-Level Supervisory Authority and Cryptocurrency Travel Rule -
European Banking Authority Offers New Guidelines on AML Compliance Officers -
Just as the United States has expanded...more
Eighth Blog Post in an Extended Series on Legislative Changes to the BSA/AML Regulatory Regime -
As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) contains major changes to the Bank Secrecy Act (“BSA”),...more
Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...more
9/20/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corruption ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Information Sharing ,
Innovative Technology ,
Money Services Business ,
Money Transmitter ,
National Security ,
Policy Statement ,
RegTech ,
Strict Compliance ,
Virtual Currency
UK-based Standard Chartered Bank (“SCB”) announced the terms of significant settlements last week with various U.S. and U.K. governmental agencies, resolving a series of related investigations into the bank’s alleged...more
4/17/2019
/ Anti-Money Laundering ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Financial Conduct Authority (FCA) ,
Fines ,
Forfeiture ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Settlement Agreements ,
Standard Chartered Bank
Federal legislators continue to struggle over the growing disconnect between increasing State legalization of the cannabis industry, and the continued illegality of cannabis under federal law....more
2/19/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Cole Memorandum ,
Decriminalization of Marijuana ,
Dispensaries ,
FFIEC ,
Financial Services Industry ,
FinCEN ,
Hemp ,
Legislative Agendas ,
Marijuana ,
Marijuana Cultivation ,
Marijuana Related Businesses ,
Medical Marijuana ,
Proposed Legislation