On September 15, 2020, the Conference of State Bank Supervisors (CSBS) announced a “one company, one exam” program for examinations of money services businesses. These businesses, spanning from money transmitters like PayPal...more
Bank Secrecy Act Update: The Financial Crimes Enforcement Network Details Its Bank Secrecy Act Enforcement Approach; Bank Regulators Provide Guidance on Their Approach to BSA Enforcement; FinCEN’s Final Rule Requiring BSA...more
9/22/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Cease and Desist Orders ,
FDIA ,
Federal Credit Unions ,
Final Rules ,
FinCEN ,
New Guidance ,
Notice of Proposed Rulemaking (NOPR) ,
U.S. Treasury
If the U.S. House of Representatives has its way, some corporations will soon be required to report information on their beneficial owners to the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”). On...more
On March 4, 2020, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its assessment of a civil monetary penalty totaling $450,000 against Michael LaFontaine, a former Chief Operational...more
The Financial Action Task Force (“FATF”) held its 31st plenary meeting during February 19-21, 2020. Among other things, the FATF classified Iran as a “high-risk jurisdiction” and called for certain countermeasures to be...more
3/4/2020
/ AML/CFT ,
Blocking Statutes ,
EU ,
FATF ,
Financial Action Task Force ,
FinCEN ,
High-Risk Countries ,
Iran ,
Money Laundering ,
New Regulations ,
Terrorist Financing Regulations
The Travel Rule is an old friend for those familiar with banking regulations and anti-money laundering rules. The Rule, first issued by FinCEN in 1995 with fiat currency in mind, requires banks and nonbank financial...more
10/2/2019
/ Anti-Money Laundering ,
Bitcoin ,
Cryptocurrency ,
Data Security ,
FATF ,
FinCEN ,
Money Services Business ,
New Guidance ,
Public Comment ,
Regulatory Requirements ,
Travel Rule ,
Virtual Currency
OFAC Provides Guidance on the Essential Components of a Risk-Based Sanctions Compliance Program -
On May 2, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury issued guidelines...more
5/6/2019
/ Audits ,
Bank Secrecy Act ,
Compliance ,
Economic Sanctions ,
Employee Training ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Patriot Act ,
Risk Assessment ,
Sanction Violations ,
U.S. Treasury
This Enforcement Action Underscores The Risks Of Sourcing Products Without Comprehensive Supply Chain Due Diligence -
On January 31, 2019, the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury...more
2/8/2019
/ China ,
Cosmetics ,
Due Diligence ,
Economic Sanctions ,
Enforcement Actions ,
Export Controls ,
Exports ,
Goods or Services ,
Imports ,
North Korea ,
Office of Foreign Assets Control (OFAC) ,
Supply Chain