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FinCEN's Proposed AML Enhancements for Money Service Businesses and Other Financial Institutions

On September 17, 2020, the Financial Crimes Enforcement Network ("FinCEN") published an Advance Notice of Proposed Rulemaking ("Notice") to obtain public comments on proposed enhancements to anti-money laundering ("AML")...more

New York Proposed Guidance on Virtual Currencies

On December 11, 2019, the New York State Department of Financial Services ("DFS") issued two proposed changes to the regime that is in place in New York for the regulation and licensing of virtual currency ("VC") businesses....more

FFIEC Examination Procedures for the Beneficial Ownership Rule

The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more

Object Lesson on How Not to Respond to Consent and Enforcement Actions

Last week, the DFS announced an enforcement action and charges against the NY Branch of Habib Bank, a Pakistani bank that had been doing business in NY for almost 40 years....more

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