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Westpac’s Alleged AML Failures Back in the News

Internal Investigation Report Stresses Lack of Intentional Misconduct – But the Investigation May Broaden - Westpac Banking Corporation (“Westpac”), Australia’s second largest retail bank, has been besieged by serious...more

FATF Issues Paper on COVID-19 Enhanced AML and Fraud Risks

On May 4, the Financial Action Task Force (“FATF”) issued a paper entitled “Covid-19-Related Money Laundering and Terrorist Financing – Risk and Policy Responses (“Paper”). ...more

Financial Action Task Force Grades America’s AML Compliance

Second Post in a Two-Post Series on Recent FATF Activity - As we just blogged, the Financial Action Task Force (“FATF”) issued a statement from its President on COVID-19 and measures to combat illicit financing during the...more

Financial Action Task Force Update: Statement on COVID-19’s Implications for AML Programs

First Post in a Two-Post Series on Recent FATF Activity - Members presumably working from home, the Financial Action Task Force (“FATF”) was active last week, first issuing its 3rd Enhanced Follow-up Report & Technical...more

FinCEN Advisory Highlights Money Laundering Risks Related to Fentanyl Trafficking

On August 21, 2019, FinCEN issued an advisory (the “Advisory”) alerting financial institutions to various financial schemes and mechanisms employed by fentanyl and synthetic opioid traffickers to facilitate the illegal...more

New FinCEN Cryptocurrency Guidance Provides Comprehensive Overview of BSA Application to Crypto Businesses

Some Answers — Producing Even More Questions - On May 9, 2019, the Financial Crimes Enforcement Network (“FinCEN”) published a comprehensive “interpretive guidance” (the “Guidance”) to “remind” businesses and individuals...more

Danske Bank Money Laundering Scandal: The Tip of the Iceberg(s)

In September, the Danish law firm Bruun & Hjejle’s report (“B&H Report”) released its internal investigation report into alleged money laundering conducted through the Estonian branch of Danske Bank (“Danske”)....more

FinCEN Director Continues to Push Value of SARs and Other BSA Data

As we just blogged, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco recently touted the value of Suspicious Activity Reports (“SARs”) in the context of discussing anti-money laundering (“AML”)...more

FinCEN Extends $3 Million Carrot to Card Club and Casino: Reduce Assessed Civil Penalty by Completing Compliance Undertakings

FinCEN announced on May 3, 2018 that Artichoke Joe’s, a card club and casino located in San Bruno, California and founded in 1916, has entered into a revised civil money penalty assessment regarding alleged deficiencies under...more

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