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FinCEN Requests Comment on Proposed Beneficial Ownership Reporting Form

Form Repeatedly Invites Response of “Unknown” As to Critical Information - The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice and request for comment (“Notice”) on the proposed form to collect and...more

Russian Oligarchs and Suspicious Financial Flows: A FinCEN Analysis

The Financial Crimes Enforcement Network (“FinCEN”) issued on December 22 a Financial Trend Analysis regarding Bank Secrecy Act (“BSA”) filings during the period of March to October 2022 (the “Report”) reflecting financial...more

OFAC and FinCEN Settle with Bittrex in Regulators’ First Parallel Virtual Currency Enforcement Actions

The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more

FATF Issues Targeted Update Report on Implementation of AML/CFT Standards on Virtual Assets

The Financial Action Task Force (“FATF”) recently issued an updated review of the implementation of its anti-money laundering (“AML”) and counter-terrorist financing (“CFT”) standards to financial activities involving Virtual...more

OCC Targets BSA/AML Compliance by Anchorage Digital Bank – Only 15 Months After Granting National Trust Bank Charter to the Crypto...

The Office of the Comptroller of the Currency (“OCC”) entered into a Consent Order (available here) with Anchorage Digital Bank (“Anchorage”), which requires Anchorage to create a compliance committee and take steps to...more

GAO Publishes Report on Nexus Between Virtual Currencies and Human and Drug Trafficking Financing

The U.S. Government Accountability Office (“GAO”) recently issued a public version of a more detailed and confidential report previously sent to Congress summarizing the GAO’s review of the use of virtual currencies to...more

Proposed Beneficial Ownership Reporting Regulations Under the CTA:  Broad and Complex

As we initially blogged, the Financial Crimes Enforcement Network (“FinCEN”) issued on December 7 a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership (“BO”) reporting requirements of the Corporate...more

FinCEN Issues First Notice of Proposed Rules for Corporate Transparency Act

Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership reporting requirements of the Corporate Transparency Act (“CTA”), which...more

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