The Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued a joint alert on June 28, 2022, warning of evasion attempts by individuals or entities to...more
Case Highlights the Role of Correspondent Bank Accounts and Circumvention of AML Programs -
Court Order Describes Seizure as a “Reckoning” for Atrocities in the Ukraine...more
On January 13, 2022, Himamauli “Him” Das, the Acting Director of FinCEN, virtually addressed the Financial Crimes Enforcement Conference hosted by the American Bankers Association and the American Bar Association. In his...more
The Second U.S. Circuit Court of Appeals, in a recent 27-page decision, held that Halkbank, the state-owned Turkish lender, cannot claim sovereign immunity under the Foreign Sovereign Immunities Act (“FSIA”) in a money...more
On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more
Government Alleges Systemic and Deliberate AML Failures -
Filings Describe Tools for CVC Exchanges to Use for Customer Due Diligence and Transaction Monitoring -
The Financial Crimes Enforcement Network (“FinCEN”) and...more
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
On February 25, 2021, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to the Bank Secretary Act/Anti-Money Laundering (“BSA/AML”) Examination Manual (the “Manual”), which provides guidance to...more
Court Rejects Halkbank’s Claim That the Foreign Sovereign Immunities Act Shields the Bank From Prosecution -
A motion to dismiss an indictment accusing Turkey’s majority state-owned Halkbank of money laundering, bank...more
10/20/2020
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Criminal Prosecution ,
Department of Justice (DOJ) ,
Extraterritoriality Rules ,
Financial Institutions ,
Foreign Sovereign Immunities Act of 1976 (FSIA) ,
Indictments ,
International Emergency Economic Powers Act (IEEPA) ,
Iran Sanctions ,
Legislative History ,
Money Laundering ,
Personal Jurisdiction ,
Sovereign Immunity ,
State-Owned Enterprises ,
U.S. Treasury