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International Trade as the New Front Against Transnational Crime

Governments worldwide are sharpening their focus on money laundering executed through international trade. Anti-money laundering obligations on entities beyond traditional financial institutions continue to expand. Companies...more

New standards against the financing of the proliferation of weapons of mass destruction

The Financial Action Task Force ("FATF"), the international standard-setting body for national anti-financial crimes regimes, recently issued new obligations for governments and, by extension, financial institutions ("FI"),...more

FinCEN Invites Comments on Anti-Money Laundering Program Effectiveness

On September 16, the US Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) seeking to update the US anti-money laundering (AML) regime. This is an historic opportunity for...more

FinCEN and US Federal Banking Agencies Clarify Risk-Based Obligations on Politically Exposed Persons

The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more

Hemp Businesses and Financial Institution Due Diligence

On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) issued guidance explaining how financial institutions can conduct due diligence for hemp-related businesses and identifying the type of information and...more

What’s Missing From BSA/AML Reform?

In recent months, support for Bank Secrecy Act/anti-money laundering ("BSA/AML") reform has gained momentum in the US Congress as more than 20 pieces of reform-related legislation circulate the financial services committees....more

Cross-Border Cannabis Investment: Managing Money Laundering Risk

Canada legalised recreational cannabis in October 2018 and it may be that other countries follow suit. UK and US investors, and those who facilitate investments in legal recreational cannabis businesses overseas, need to be...more

AML Information Sharing in a Technology-Enabled and Privacy-Conscious World

Financial firms play an integral role in preventing, identifying, investigating and reporting criminal activity, including terrorist financing, money laundering, and many other finance-related crimes. It is a critical role...more

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