“Sanctions Bill from Hell” Targets Real Estate Deals -
On February 13, 2019, Sen. Lindsay Graham (R – S.C.) introduced S.482 – the Defending American Security from Kremlin Aggression Act of 2019 (“DASKAA”), a bill intended...more
3/1/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
Cyber Crimes ,
Economic Sanctions ,
Geographic Targeting Order ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Real Estate Investments ,
Real Estate Transactions ,
Russia
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
A recent decision out of the United States District Court for the Eastern District of Virginia adjudicating a seemingly straight-forward alleged fraud and money laundering scheme reminds us that money laundering charges still...more
As we have blogged, the United States Attorney’s Office for the Southern District of Florida is pursuing charges against eight individuals for allegedly conspiring to launder $1.2 billion embezzled from a Venezuelan...more
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)
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
The Tale of an AML BSA Exam Gone Wrong -
As we have blogged, the Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease...more
3/21/2018
/ Appeals ,
Banking Sector ,
BSA/AML ,
Cease and Desist ,
Cooperative Compliance Regime ,
FDIC ,
FFIEC ,
Filing Requirements ,
Financial Institutions ,
Internal Controls ,
Money Laundering ,
Risk Management ,
Suspicious Activity Reports (SARs)
The Ninth Circuit Court of Appeals recently upheld the decision of the Board of Directors of the Federal Deposit Insurance Corporation (“FDIC”) to issue a cease and desist order against California Pacific Bank (the “Bank”)...more
3/20/2018
/ Administrative Law Judge (ALJ) ,
Appeals ,
Banking Sector ,
Banks ,
BSA/AML ,
Cease and Desist ,
Constitutional Challenges ,
FDIC ,
FFIEC ,
Money Laundering ,
Regulatory Violations ,
Suspicious Activity Reports (SARs)
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
Attorney General Sessions Announces Rescission of Obama Administration Policies on Marijuana Enforcement; Financial Institutions Lose Grounds to Permit Financial Transactions with Marijuana Businesses....more
1/5/2018
/ Banking Sector ,
BSA/AML ,
Cole Memorandum ,
Criminal Prosecution ,
Decriminalization of Marijuana ,
Department of Justice (DOJ) ,
Dispensaries ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Marijuana ,
Marijuana Related Businesses ,
Medical Marijuana ,
Money Laundering ,
Policy Memorandums ,
Regulatory Standards ,
Suspicious Activity Reports (SARs) ,
Trump Administration
Part Three of a Three-Part Series -
In the third and final part of this series on marijuana-related businesses (“MRBs”), we explore how the Securities and Exchange Commission (“SEC”) and the Department of Justice (“DOJ”)...more
7/13/2017
/ Banking Sector ,
BSA/AML ,
Department of Justice (DOJ) ,
Dispensaries ,
Financial Institutions ,
Investment ,
Marijuana ,
Marijuana Related Businesses ,
NYSE ,
Retail Market ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Violations ,
Trading Platforms ,
Unregistered Securities
Signaling increased oversight of nonprofit organizations, the New York Attorney General’s Office recently began to scrutinize the management and operation of New York nonprofits in an effort to head off potential crises...more