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
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 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
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
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
8/2/2019
/ Business E-Mail Compromise (BEC) ,
Federal Reserve ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Identity Theft ,
Innovative Technology ,
Know Your Customers ,
Money Laundering ,
Personally Identifiable Information ,
Suspicious Activity Reports (SARs) ,
Vulnerability Assessments
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