On June 17, 2020, the Financial Conduct Authority (“FCA”), the non-governmental financial regulator in the United Kingdom, issued a Final Notice to Commerzbank London (the “Bank”), a branch of the large German business bank,...more
In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more
3/5/2020
/ AML/CFT ,
Anti-Money Laundering ,
Broker-Dealer ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
FATF ,
Financial Institutions ,
FinCEN ,
Foreign Investment ,
Geographic Targeting Order ,
Innovative Technology ,
Legal Representatives ,
Money Laundering ,
Natural Person Requirement ,
Real Estate Investments ,
Real Estate Market ,
Real Estate Transactions ,
Regulatory Requirements ,
Service Professionals ,
Title Insurance ,
U.S. Treasury ,
Virtual Currency
First in a Two-Post Series -
The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more
2/28/2020
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Casinos ,
Corruption ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Digital Assets ,
FATF ,
Financial Institutions ,
FinCEN ,
Foreign Correspondent Banking ,
Money Laundering ,
Money Services Business ,
Proposed Rules ,
Real Estate Transactions ,
Rulemaking Process ,
Securities Transactions ,
Strategic Enforcement Plan ,
Terrorism Funding ,
Terrorist Financing Regulations ,
Transparency ,
U.S. Treasury ,
Vulnerable Victims ,
White Collar Crimes
Last week, the House Financial Services Committee released three proposed bills to codify many of the reform ideas that have arisen in an ongoing conversation among financial agencies, law enforcement, financial institutions,...more
3/15/2019
/ AML/CFT ,
BSA/AML ,
Financial Crimes ,
Financial Regulatory Reform ,
Financial Services Committee ,
Financial Services Industry ,
FinCEN ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Rulemaking Process ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations ,
Whistleblowers
The Financial Crimes Enforcement Network (FinCEN) released prepared remarks delivered by FinCEN director, Kenneth A. Blanco, at the Securities Industry and Financial Markets Association (SIFMA) Anti-Money Laundering (AML) &...more
2/7/2019
/ BSA/AML ,
Cooperative Compliance Regime ,
Employee Training ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Internal Controls ,
Money Laundering ,
Policy Statement ,
Regulatory Agenda ,
Terrorist Financing Regulations
Earlier this month, the District Court for the Central District of California imposed a prison sentence of one year and a day, with three years of supervised release, on defendant Theresa Lynn Tetley, who had pleaded guilty...more
7/24/2018
/ Bank Secrecy Act ,
Bitcoin ,
Criminal Convictions ,
Cryptocurrency ,
Darknet ,
Digital Currency ,
Enforcement Actions ,
Financial Instruments ,
FinCEN ,
Guilty Pleas ,
Money Laundering ,
Money Services Business ,
Money Transmitter ,
Registration Requirement ,
Statutory Violations ,
Virtual Currency
The Financial Crimes Enforcement Network (“FinCEN”) recently advised that a financial institution is not required to file a Suspicious Activity Report (“SAR”) based solely upon a customer’s inquiry into or participation in a...more
FinCEN recentlty announced entry of a $2 million assessment against Lone Star National Bank, a private bank operating out of Texas, for the bank’s allegedly willful violations of the Bank Secrecy Act (“BSA”) and inadequate...more
11/8/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Due Diligence ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Foreign Correspondent Banking ,
Mexico ,
Patriot Act ,
Regulatory Oversight ,
Suspicious Activity Reports (SARs)
This post discusses individual liability in AML/BSA enforcement, which is an area of increasing attention. Indeed, according to public statements by the government, individual liability is the focus of enhanced scrutiny...more
5/19/2017
/ Banking Sector ,
Broker-Dealer ,
BSA/AML ,
Department of Justice (DOJ) ,
Derivative Suit ,
FinCEN ,
Fraud ,
Individual Accountability ,
Money Laundering ,
Money Transmitter ,
Moneygram ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Suspicious Activity Reports (SARs) ,
Western Union ,
White Collar Crimes ,
Yates Memorandum
On January 19, 2017, the Western Union Company (“Western Union” or the “Company”) entered into a deferred prosecution agreement (“DPA”) with the Department of Justice (“DOJ”), in which Western Union admitted to willful...more
3/15/2017
/ Banking Sector ,
BSA/AML ,
Class Action ,
Deferred Prosecution Agreements ,
Derivative Suit ,
Financial Services Industry ,
FinCEN ,
Foreign Corrupt Practices Act (FCPA) ,
Form 10-K ,
Misleading Statements ,
Money Laundering ,
Money Transfer ,
Securities and Exchange Commission (SEC) ,
Western Union ,
Wire Fraud