The US House of Representatives has passed stablecoin legislation as part of “Crypto Week” on Capitol Hill. S. 1582, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS or the Act), passed the US...more
On January 20, 2025, President Donald J. Trump signed Executive Order 14157, “Designating Cartels and Other Organizations as Foreign Terrorist Organizations and Specially Designated Global Terrorists” (EO 14157)....more
4/23/2025
/ Anti-Money Laundering ,
Cartels ,
Civil Liability ,
Corporate Liability ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Executive Orders ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
SDN List ,
Significant Transnational Criminal Organization ,
Terrorist Organizations
On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more
7/25/2024
/ AML/CFT ,
Anti-Money Laundering ,
Anti-Terrorism Financing ,
Compliance ,
FDIC ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Agencies ,
FinCEN ,
NCUA ,
NPRM ,
OCC ,
Proposed Rules ,
Suspicious Activity Reports (SARs)
On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more
3/22/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Popular ,
Proposed Regulation ,
Reporting Requirements ,
Securities and Exchange Commission (SEC)
On November 1, 2021, the President’s Working Group on Financial Markets (PWG) - along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) - published the Report on...more
11/16/2021
/ Anti-Money Laundering ,
Blockchain ,
CFTC ,
Cross-Border ,
Cryptocurrency ,
Exchange Rates ,
FDIC ,
FinCEN ,
FSOC ,
Information Reports ,
Legislative Agendas ,
OCC ,
Payment Systems ,
Prudential Regulation Authority (PRA) ,
Regulatory Agenda ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Stablecoins
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
9/24/2021
/ Advisory Opinions ,
AML/CFT ,
Anti-Money Laundering ,
Compliance ,
Cryptocurrency ,
Currency Exchange ,
Cybersecurity Information Sharing Act (CISA) ,
Economic Sanctions ,
FinCEN ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia ,
SDN List ,
U.S. Treasury ,
Virtual Currency
The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more
7/15/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Biden Administration ,
Compliance ,
Cybersecurity ,
Drug Trafficking ,
Enforcement Priorities ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Human Trafficking ,
No-Action Letters ,
Nonbank Firms ,
Ransomware ,
Significant Transnational Criminal Organization ,
Terrorism Funding ,
Virtual Currency
On June 3, 2021, President Biden issued a National Security Memorandum establishing the fight against corruption both at home and abroad as a core United States national security interest and directing the development of a...more
6/9/2021
/ Anti-Corruption ,
Anti-Money Laundering ,
Biden Administration ,
Compliance ,
Corporate Governance ,
Cross-Border Transactions ,
Economic Sanctions ,
Financial Institutions ,
Foreign Corporations ,
Government Agencies ,
National Security ,
NDAA ,
Patriot Act ,
Presidential Memorandum ,
Transparency
Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more
2/12/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
NDAA ,
Patriot Act ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
Two recent actions by the Office of the Comptroller of the Currency (OCC) - one enforcement action and one interpretive note - focus attention on the kinds of anti–money laundering (AML) controls needed for banks to custody...more
8/7/2020
/ Anti-Money Laundering ,
BSA/AML ,
Compliance ,
Consent Order ,
Cryptoassets ,
Cryptocurrency ,
Custody ,
Enforcement Actions ,
Financial Institutions ,
FinCEN ,
OCC
In this alert, we summarize recent guidance from federal regulators and self-regulatory organizations - including the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), the Office of...more
4/28/2020
/ Anti-Money Laundering ,
Bank Secrecy Act ,
CARES Act ,
Compliance ,
Coronavirus/COVID-19 ,
Financial Crimes ,
Financial Fraud ,
Financial Institutions ,
Financial Regulatory Agencies ,
Financial Stimulus ,
Paycheck Protection Program (PPP)
Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions matters continue to be a core focus of regulators, law enforcement agencies, policymakers and Congress, and the story of the Obama and Trump Administrations on...more
7/29/2019
/ Anti-Money Laundering ,
BSA/AML ,
Cuba ,
Customer Due Diligence (CDD) ,
Drug Trafficking ,
Economic Sanctions ,
Enforcement Actions ,
FinCEN ,
Human Trafficking ,
Iran ,
Magnitsky Act ,
Nicaragua ,
North Korea ,
Russia ,
Sudan ,
Trump Administration ,
Venezuela ,
Virtual Currency
The myriad—and conflicting—state, federal and international laws governing the burgeoning marijuana industry have created a complicated legal landscape for financial institutions. In the United States, most states have...more
2/8/2019
/ Anti-Money Laundering ,
Canada ,
Cannabidiol (CBD) oil ,
Cole Memorandum ,
Controlled Substances Act ,
Decriminalization of Marijuana ,
Farm Bill ,
Financial Institutions ,
FinCEN ,
Food and Drug Administration (FDA) ,
Hemp ,
Marijuana ,
Marijuana Related Businesses ,
Proceeds of Crime Act 2002 (POCA) ,
Regulatory Agenda ,
Risk Management ,
State and Local Government ,
Suspicious Activity Reports (SARs)