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DOJ Files Lawsuit for $60 Million in Civil Penalties for Alleged BSA Violations by Crypto “Mixer”

On October 19, 2022, the U.S. Attorney’s Office for D.C., on behalf of the Financial Crimes Enforcement Network (“FinCEN”), filed a civil complaint against Larry Dean Harmon (“Harmon”), seeking $60 million in civil penalties...more

Treasury Report:  No Immediate Need for BSA Regulations for the Art Industry

But AML Concerns Linger As To “High End” Art and NFTs - On February 4, 2022, the U.S. Department of the Treasury published a study (the “Study”) on the facilitation of money laundering (“ML”) and terrorist financing (“TF”)...more

FinCEN Seeks Comments on Corporate Transparency Act Implementation

Seventh Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime - On April 5, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued an advance notice of proposed rulemaking (“ANPRM”) to...more

First Principles: AMLA Expands Stated Purpose of BSA and Exam Priorities

Revisions to BSA Will Inform Regulatory Examinations for Years to Come - Third Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime - As we have blogged, the Anti-Money Laundering Act of 2020...more

FinCEN Issues Advisory on Human Trafficking

Advisory Suggests that COVID-19 Pandemic Exacerbates Conditions Contributing to Trafficking - The Financial Crimes Enforcement Network (“FinCEN”) recently issued an Advisory on Identifying and Reporting Human Trafficking and...more

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