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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

FinCEN Withdraws Designation of ABLV Bank as Foreign Financial Institution “Of Primary Money Laundering Concern”

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

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

Treasury Asks the Eleventh Circuit to Uphold the CTA and Congressional Authority

We previously blogged on the lawsuit filed by the National Small Business Association (“NSBA”) and one of its individual members, which sought to challenge the constitutionality of the Corporate Transparency Act (“CTA”). Most...more

Crypto Couple Plead Guilty to Money Laundering Conspiracy

In February 2022, we blogged on the seizure of a record $3.6 billion in stolen Bitcoin (“BTC”) and an accompanying criminal complaint, charging husband and wife Ilya “Dutch” Lichtenstein and Heather “Razzlekhan” Morgan with...more

Federal Reserve and FinCEN Raise Alarms Regarding Technology-Assisted Financial Fraud

The Federal Reserve and the Financial Crimes Enforcement Network, or FinCEN, both recently issued reports addressing worrisome trends in technology-assisted financial fraud.  The reports to engage the financial services...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

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