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
The judgment delivered by the Court of Appeal of Grenoble on 26 June 2025 marks a significant development in the jurisprudence concerning the liability of digital asset service providers (DASPs)....more
The Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act) was recently signed into law by President Trump, establishing a regulatory framework for payment stablecoins and their issuers. The...more
The European Union Anti-Money Laundering ("AML") package includes Regulation (EU) 2024/1620 of the European Parliament and of the Council of May 31, 2024, establishing the Authority for Anti-Money Laundering and Countering...more
Guernsey has established itself as a sophisticated, stable jurisdiction for the structuring of alternative investment funds and bespoke vehicles. Among its suite of offerings, Guernsey permits the formation of unregulated...more
Pending completion of its recommended actions under the BVI Mutual Evaluation Report published by the Caribbean FATF in February 2024, the BVI has been included on the FATF's list of "jurisdictions under increased...more
The Federal Reserve Bank of New York (FRBNY) has cemented its role as a global financial watchdog, using its influence to safeguard the integrity of the U.S. dollar and the broader international financial system. Recent...more
On January 28, 2025, FINRA published its 2025 Annual Regulatory Oversight Report (the “Report”) as “an up-to-date, evolving resource or library of information for firms” that highlights specific industry trends, new...more
The European Union this year finalized significant revisions to its rules countering money laundering and terrorist financing (the AML Package). In addition to strengthening the existing regulatory framework, the AML Package...more
On September 19th, 2024, the CSSF published its 2023 annual report, highlighting key regulatory challenges, particularly in the realm of crypto-assets following the implementation of the Markets in Crypto-Assets Regulation...more
While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more
On January 17, 2024, the Council of the European Union (Council) and the European Parliament (Parliament) announced that a political agreement had been reached on (i) a new Regulation setting forth a single anti-money...more
The Cayman Islands recently received an early Holiday gift when the EU Commission published a regulation in mid-December paving the way to remove Cayman from its list of ‘high-risk’ countries for AML/CFT purposes. The...more
Key developments of interest over the last month include: the UK FCA’s publication of a portfolio letter to payments and e-money firms; the U.S. Federal Reserve announcing the July 2023 launch of its FedNow Service; and...more
On December 14, Senators Elizabeth Warren (D-Mass.) and Roger Marshall (R-Kan.) introduced in the U.S. Senate a new bipartisan bill, titled "Digital Asset Anti-Money Laundering Act of 2022" (the “Bill”), intended to curb the...more
Hong Kong has traditionally been a hub for digital asset businesses in the region. As regulators in Hong Kong are working to tighten the regulatory regime on virtual asset exchanges, market players and investors seeking to...more
The Financial Industry Regulatory Authority (FINRA) issued a regulatory notice on Oct. 8, 2021, encouraging its broker-dealer members to review and prepare to incorporate into their own compliance programs the national...more
The United Arab Emirates (the “UAE”) has announced a new division of its court system established specifically to hear cases relating to money laundering and financial crime. This new Court, an integral element of the UAE’s...more
Recent news coverage has highlighted two potentially watershed moments in the FinTech revolution: the rise of Decentralized Finance (“DeFi”) that challenges both traditional FinTechs and legacy financial institutions alike,...more
La Ley ALD del 2020 (“AML Act of 2020”) incluye la creación de los “Attachés del Tesoro” (SEC. 6106, designados por el Departamento del Tesoro de los Estados Unidos) y los “Enlaces de la Unidad de Inteligencia Financiera...more
The AML Act of 2020 includes the creation of “Treasury Attachés” (SEC. 6106, appointed by the US Treasury Department) and the “Foreign Financial Intelligence Unit Liaisons” (SEC. 6108, appointed by FinCEN) to be stationed...more
Antes de la aprobación de la LEY AML del 2020 (“AML ACT of 2020”), el Departamento del Tesoro de los EE. UU. y el Departamento de Justicia de los EE. UU. (“DOJ”) tenían la autoridad para citar (“subpoena”) a los bancos...more
Before passage of the AML ACT of 2020 (the “ACT”), The US Department of the Treasury, and the US Justice Department (DOJ) had US legal authority to subpoena foreign banks with US correspondent accounts for related US records...more
Regulators consult on anti-money laundering guidelines and issue guidance on cybersecurity, best execution, and senior management accountability. This blog post summarizes key regulatory developments in Hong Kong and...more
A Director of Enforcement at the Financial Conduct Authority (FCA) has set out some of the key challenges the regulator expects in its new role as AML/CTF (anti-money laundering/counter terrorist financing) supervisor for...more
On 2/6/2020, the U.S. Department of the Treasury issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy). The purpose of the 2020 Strategy is to...more