On August 5, the FDIC announced that banks it supervises can comply with Bank Secrecy Act (BSA) requirements to obtain identity information from new customers by using a pre-populated form, provided that the person opening...more
The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more
4/27/2022
/ Bribery ,
BSA/AML ,
Cryptocurrency ,
Economic Sanctions ,
Embezzlement ,
Extortion ,
Financial Institutions ,
FinCEN ,
Foreign Official ,
Misappropriation ,
Money Laundering ,
New Guidance ,
Offshore Funds ,
Public Corruption ,
Ransomware ,
Russia ,
Shell Corporations ,
Suspicious Activities ,
Suspicious Activity Reports (SARs)
On January 1, 2021, Congress enacted a broad range of anti-money laundering (“AML”) reforms within the Anti-Money Laundering Act of 2020 (the “AML Act”), as part of the National Defense Authorization Act for Fiscal Year 2021...more
2/4/2021
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corruption ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Money Laundering ,
Terrorist Financing Regulations ,
Whistleblowers ,
White Collar Crimes
Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more
10/9/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Corruption ,
Financial Crimes ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Public Comment ,
Regulatory Agenda ,
Risk Assessment ,
White Collar Crimes
The Financial Crimes Enforcement Network (FinCEN) and federal banking regulators recently issued a Joint Statement intended to clarify the due diligence obligations of banks under the Bank Secrecy Act (BSA) regarding...more
9/17/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Customer Due Diligence (CDD) ,
FFIEC ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Joint Statements ,
Politically Exposed Person (PEPs) ,
Regulatory Requirements ,
Risk-Based Approaches
Earlier this month, senior officials of the global money laundering and terrorist financing watchdog—the Financial Action Task Force (FATF)—issued a paper identifying challenges, good practices, and policy responses to new...more
I. Background -
Sweden’s financial supervisory authority (“SFSA”) recently fined Swedbank AB a record 4 billion Swedish kronor (approximately $386 million) for deficiencies in its anti-money laundering (“AML”) processes...more
4/19/2020
/ Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corruption ,
Cross-Border Transactions ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Know Your Customers ,
Money Laundering ,
Sweden ,
White Collar Crimes
On March 4, 2020, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) assessed a civil monetary penalty of $450,000 against Michael LaFontaine, the former Chief Operational Risk Officer and...more
A recent federal criminal action shows the depth of the U.S. government’s concern about the use of cryptocurrency (or virtual currency) to violate economic sanctions laws and the lengths to which it will go to charge such...more
1/24/2020
/ Anti-Money Laundering ,
Bitcoin Mining ,
BSA/AML ,
CFTC ,
Corruption ,
Cryptocurrency ,
Currency Exchange ,
Digital Currency ,
Economic Sanctions ,
Financial Transactions ,
FinCEN ,
Geo-Blocking ,
Jurisdiction ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Oversight ,
Risk Management ,
Sanction Violations ,
SDN List ,
Securities and Exchange Commission (SEC) ,
Strict Compliance ,
Strict Liability ,
Virtual Currency