In a significant policy shift, Deputy Attorney General Todd Blanche issued a memorandum titled “Ending Regulation By Prosecution,” on April 7, 2025, signaling a change in the Department of Justice’s (DOJ) approach to digital...more
4/16/2025
/ Criminal Prosecution ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
Financial Crimes ,
Investment ,
National Security ,
Regulatory Reform ,
Securities Regulation ,
Trump Administration
Recent developments in the world of crypto have come at a rapid pace to open 2025 not only signaling but, in some instances, explicitly declaring the Trump Administration’s intent to significantly relax or eliminate...more
3/10/2025
/ Anti-Money Laundering ,
Cryptocurrency ,
Digital Assets ,
Enforcement Actions ,
Executive Orders ,
Financial Regulatory Reform ,
FinCEN ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Trump Administration
Does it matter if a law is valid if the Government refuses to enforce it? For months, we have watched (and blogged on) courts grappling with the constitutionality and enforceability of the Corporate Transparency Act (“CTA”)....more
Developments concerning the enforceability and enforcement of the CTA came at a rapid clip last week. As things stand, the government may enforce the CTA pending a Texas court appeal in Smith v. U.S. Department of the...more
The new administration has signaled that the Department of Justice (“DOJ”) will significantly shift its approach to criminal corporate enforcement. Specifically, on February 5, 2025, newly-confirmed United States Attorney...more
2/14/2025
/ Anti-Money Laundering ,
Corporate Governance ,
Corporate Misconduct ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Executive Orders ,
Financial Institutions ,
Foreign Corrupt Practices Act (FCPA) ,
Money Laundering ,
Regulatory Agenda ,
Regulatory Reform ,
Trump Administration
As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more
11/27/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CFTC ,
Consent Order ,
Cryptocurrency ,
Department of Justice (DOJ) ,
Digital Assets ,
Enforcement Actions ,
FinCEN ,
Guilty Pleas ,
International Emergency Economic Powers Act (IEEPA) ,
Money Laundering ,
Money Services Business ,
Office of Foreign Assets Control (OFAC) ,
Plea Agreements ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934 ,
Suspicious Activity Reports (SARs)
On June 5, 2023, the SEC filed an extensive civil complaint against Binance Holdings Limited, its assorted affiliates and its beneficial owner and CEO, Changpeng Zhao, alleging multiple violations of the Securities Act of...more
Summary -
The Securities and Exchange Commission (SEC) announced today that it has settled its case against The Cheesecake Factory charging the national restaurant chain with providing misleading disclosures in filings—the...more
Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud?
The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more
9/3/2020
/ Beneficial Owner ,
Borrowers ,
BSA/AML ,
CARES Act ,
Coronavirus/COVID-19 ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Housing Administration (FHA) ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Agencies ,
FinCEN ,
Fraud ,
Government Investigations ,
HUD ,
Lenders ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
SBA ,
U.S. Treasury
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
6/15/2020
/ AML/CFT ,
Anti-Money Laundering ,
Australia ,
Banks ,
Due Diligence ,
Enforcement Actions ,
Financial Institutions ,
Foreign Correspondent Banking ,
Internal Investigations ,
Money Laundering ,
Money Transfer ,
Terrorist Financing Regulations
First Post in a Two-Part Series -
Recent actions in the crypto realm demonstrate that authorities and regulators have not slackened their commitment to applying and enforcing Anti-Money Laundering (“AML”) laws and...more
5/10/2019
/ BitLicense ,
BSA/AML ,
Cryptocurrency ,
Currency Transaction Reports (CTR) ,
Darknet ,
Enforcement Actions ,
Money Laundering ,
Money Services Business ,
NYDFS ,
Peer-to-Peer ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Virtual Currency
More Allegations of Nordic Malfeasance Surface as Private Party Lawsuits Beset Danske Bank and SwedBank Gets Sucked into Unfolding Scandal....more
4/5/2019
/ American Depository Receipts (ADRs) ,
BSA/AML ,
Class Action ,
Danske Bank ,
Enforcement Actions ,
Estonia ,
Financial Crimes ,
Financial Transactions ,
Investment Opportunities ,
Money Laundering ,
Rule 10(b) ,
Rule 10b-5 ,
Securities Fraud
As we blogged yesterday, British Columbia’s (“B.C.”) Attorney General David Eby recently released an independent and very detailed report examining money laundering in B.C.’s gaming industry and providing 48 recommendations...more
7/17/2018
/ BSA/AML ,
Canada ,
Casinos ,
Currency Transaction Reports (CTR) ,
Enforcement Actions ,
Financial Crimes ,
FinCEN ,
Gambling ,
Gaming ,
Money Laundering ,
Regulatory Oversight ,
Regulatory Standards ,
Suspicious Activity Reports (SARs)
On May 16, 2018, the Securities Exchange Commission (“SEC”) announced it had settled charges against a registered broker-dealer, its clearing firm, and its chief compliance and anti-money laundering (“AML”) officer brought...more
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
As we previously have blogged, the Financial Crimes Enforcement Network (“FinCEN”) became one of the first regulators to wade into the regulation of cryptocurrency when it released interpretive guidance in March 2013 stating...more
3/9/2018
/ AML/CFT ,
Bitcoin ,
Blockchain ,
Broker-Dealer ,
CFTC ,
Cryptocurrency ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Enforcement Actions ,
Financial Instruments ,
Financial Markets ,
FinCEN ,
Initial Coin Offering (ICOs) ,
Interpretive Rule ,
Money Services Business ,
Money Transmitter ,
Mutual Funds ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
Token Sales ,
Virtual Currency