We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more
7/25/2025
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Regulatory Agencies ,
Regulatory Reform ,
Regulatory Requirements ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
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
The Fifth Circuit has granted the government’s request to stay temporarily the order and injunction issued by the United States District Court for the Eastern District of Texas, which had issued a nationwide stay prohibiting...more
12/24/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Constitutional Challenges ,
Corporate Transparency Act ,
Corruption ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Stays
Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more
9/13/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Reporting Requirements ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
FinCEN’s recent preliminary rulemaking aims to enhance and modernize regulations with requirements and priorities that affect a broad range of “financial institutions” across industries—but lacks concrete guidance on...more
7/26/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Chevron Deference ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Popular ,
Regulatory Agenda ,
Risk Assessment ,
Terrorist Financing Regulations
The Financial Crimes Enforcement Network (“FinCEN”) recently complied with two important deadlines under the Anti-Money Laundering Act (“AML Act”) — issuing national priorities for AML and countering the financing of...more
The Financial Crimes Enforcement Network (“FinCEN”) just issued another Advisory pertaining to two consumer fraud schemes exacerbated by the COVID-19 pandemic. ...more
On May 18, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advisory “to alert financial institutions to rising medical scams related to the COVID-19 pandemic. This [A]dvisory contains red flags, descriptions of...more
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
5/11/2020
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
CARES Act ,
Coronavirus/COVID-19 ,
Corruption ,
FATF ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Paycheck Protection Program (PPP)
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
4/13/2020
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Coronavirus/COVID-19 ,
Corruption ,
Cross-Border Transactions ,
FATF ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Money Laundering ,
Terrorism Funding ,
Terrorist Financing Regulations
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
4/13/2020
/ AML/CFT ,
Anti-Corruption ,
Anti-Money Laundering ,
BSA/AML ,
Coronavirus/COVID-19 ,
Cross-Border Transactions ,
FATF ,
Financial Crimes ,
Financial Institutions ,
Know Your Customers ,
Money Laundering ,
Terrorism Funding ,
Terrorist Financing Regulations
The Financial Crimes Enforcement Network (“FinCEN”) just issued a release, entitled “The Financial Crimes Enforcement Network (FinCEN) Encourages Financial Institutions to Communicate Concerns Related to the Coronavirus...more
3/17/2020
/ China ,
Coronavirus/COVID-19 ,
Crisis Management ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Infectious Diseases ,
Insider Trading ,
Money Laundering ,
Public Health ,
Scams
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
8/30/2019
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Convertible Virtual Currencies (CVCs) ,
Cross-Border Transactions ,
Depository Institutions ,
Digital Wallets ,
Drug & Alcohol Abuse ,
Drug Trafficking ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Money Services Business ,
Opioid ,
Prescription Drugs ,
Risk Management ,
Suspicious Activity Reports (SARs)
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
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
11/30/2018
/ Anti-Money Laundering ,
Corruption ,
Danske Bank ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
Internal Controls ,
Money Laundering ,
Non-Disclosure Agreement ,
Russia ,
Vladimir Putin ,
Whistleblowers ,
White Collar Crimes
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
On July 24, 2018, the United States Attorney’s Office for the Southern District of Florida unsealed a criminal complaint (the “Complaint”) charging eight individuals with conspiracy to commit money laundering under 18 U.S.C....more
8/3/2018
/ Criminal Conspiracy ,
Criminal Prosecution ,
Currency Exchange ,
Department of Homeland Security (DHS) ,
Department of Justice (DOJ) ,
Embezzlement ,
Energy Sector ,
Financial Crimes ,
Foreign Nationals ,
Foreign Official ,
Indictments ,
Joint Venture ,
Money Laundering ,
Racketeering ,
Real Estate Investments ,
Shell Corporations ,
Venezuela
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)
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