Compliance Tip of the Day: Citibank and Continuous Monitoring
Business Better Podcast Episode: FinCEN’s Notice of Proposed Regulations to Strengthen and Modernize AML/CFT Compliance Programs
Crypto Year in Review 2022: Crypto Enforcement and the U.S. Treasury - The Crypto Exchange Podcast
La regulación global de las criptomonedas ha pasado de la teoría a la aplicación real. El Marco de Reporte de Criptoactivos (CARF) de la OCDE y los estándares reforzados para Proveedores de Servicios de Activos Virtuales...more
Global cryptocurrency regulation has shifted from theory to enforcement. The OECD’s Crypto-Asset Reporting Framework (CARF) and strengthened Virtual Asset Service Provider (VASP) standards are redefining oversight...more
The Wolfsberg Group (the Group) has released a statement reaffirming its commitment to the risk-based approach (RBA) for financial crime risk management. Further to its 2006 RBA guidance, and in line with the Financial Action...more
On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more
On September 9, 2024, a mediator from the French Financial Markets Authority (AMF) issued conclusions regarding the dispute over the closure of a client’s securities account. The account was closed because the client had...more
On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more
FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more
Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more
Following the removal of the Cayman Islands from the Financial Action Task Force's list of "jurisdictions under increased monitoring" in October 2023, on 12 December 2023, the European Commission adopted the Commission...more
Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more
The UAE is the Middle East’s leading financial center and a global hub for trade, particularly in gold and precious metals. This large presence within the global financial system makes it a target for financial crime,...more
...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more
El aumento de los costos de cumplimiento, las estructuras de clientes corporativos difíciles de entender, las multas y sanciones, el cambio de la responsabilidad corporativa a la responsabilidad individual y las...more
Australia has implemented “Phase 1.5” in its anti-money laundering and counter-terrorism reforms. However, Australia’s long-awaited and much-debated “second tranche” of reforms remains out of grasp. ...more
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
The Financial Action Task Force (FATF) on February 21, 2020, reintroduced its call for countries to impose countermeasures to protect themselves from illicit finance threats emanating from Iran. The call for countermeasures...more
On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more
On October 25, 2019, FinCEN issued a final rule imposing the Fifth Special Measure against the Islamic Republic of Iran as a “jurisdiction of primary money laundering concern” (“Final Rule”) under Section 311 of the USA...more
The European Supervisory Authorities have published a joint opinion on the current anti-money laundering and counter-terrorist financing risks posed to the EU financial sector. The opinion is published in accordance with the...more
Deficiencies in Anti-Money Laundering (AML) frameworks and policies have triggered a significant number of Financial Institutions (FIs) to de-risk. ...more
On September 15th, FinCEN issued its latest “Advisory on FATF-Identified Jurisdictions with AML/CTF Deficiencies.” The FATF, or the Financial Action Task Force, is a 37-member intergovernmental body, including the United...more
On August 30, 2016, the U.S. Department of the Treasury and four U.S. federal banking regulators sought to correct a problem—at least in part one of their own creation—by issuing a “Joint Fact Sheet on Foreign Correspondent...more
Because they are known as “gatekeepers” in the financial industry, Professional Service Providers (PSPs), Bankers, Brokers, Realtors, Casino Managers, Trust Fund Managers, Money Managers, etc., carry a level of responsibility...more
On March 21, 2016, the Financial Crimes Enforcement Network (FinCEN) issued an Advisory (FIN-2016-A002) on the Financial Action Task Force (FATF)-identified jurisdictions with strategic deficiencies in anti-money laundering...more