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FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

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

EDNY Upholds Money Laundering Charge Against Defense Attack Under Ciminelli

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

Will Ciminelli’s Impact on Wire Fraud Cases Ripple Out to Bank Fraud?

In January, we blogged on the Southern District of New York sentencing of Danske Bank to three years of probation and a forfeiture of $2.059 billion. As we noted at the time, the bank was charged with bank fraud, rather than...more

New AML Whistleblower Program Highlighted by FinCEN Acting Director

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

FINRA Reminds Firms to Prepare for New AML/CFT Priorities

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

Review, then Reform? AMLA Charts a Path for the Future of SARs and CTRs

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

FinCEN Deputy Director Stresses Technological Innovation, Virtual Currency Enforcement and the U.S. Culture of Compliance

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

Congressional Funding Bill Pursues Approval of Financial Services for Marijuana Industry Through the (Temporary) Backdoor

As we have blogged, there is perplexing, significant and ongoing uncertainty regarding just how federal criminal and Bank Secrecy Act laws will be – or will not be – enforced against financial institutions providing banking...more

Financial Services and the Marijuana Industry: the U.S. House Mulls Regulatory Reform for Financial Institutions and...

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

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