News & Analysis as of

Anti-Money Laundering Due Diligence

Hogan Lovells

Art, sanctions and suspicion: What the Ojiri case tells us about risk and responsibility in the regulated sector

Hogan Lovells on

The recent conviction of London-based art dealer Oghenochuko Ojiri marks a watershed moment for financial crime enforcement in the UK's regulated sector. For the first time, a conviction has been secured under section 21A of...more

A&O Shearman

Wolfsberg Group issues statement on the RBA for financial crime risk management

A&O Shearman on

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

Foley & Lardner LLP

Key Measures for Mexican Entities to Prevent FinCEN Scrutiny

Foley & Lardner LLP on

The recent Orders issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on June 25, 2025, designating CIBanco, Intercam, and Vector as institutions of primary money laundering concern,...more

Hogan Lovells

PEP talk: The UK FCA issues final guidance on the treatment of politically exposed persons

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The Financial Conduct Authority (“the FCA”) has published final guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes, which updates its Guidance issued in 2017 (“the 2017...more

Cadwalader, Wickersham & Taft LLP

Chasing the Clock, July 2025 - Need an Expedited Closing? Let’s Talk About It.

The growing need for quick capital in today’s fluid investing market has led to a recent trend of requests for expedited closings with aggressive timelines and inflexible targeted closing dates. While banks certainly strive...more

K&L Gates LLP

Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

K&L Gates LLP on

On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

Baker Botts L.L.P. on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more

Thomas Fox - Compliance Evangelist

Compliance into the Weeds: Sanctions Compliance Failures: Lessons from Harman International and Interactive Brokers

The award-winning Compliance into the Weeds is the only weekly podcast that takes a deep dive into a compliance-related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting...more

The Volkov Law Group

Episode 377 — Refocusing Due Diligence on Cartel and TCOs

The Volkov Law Group on

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge – the urgent need to unravel their supply chains and the immediate...more

Foodman CPAs & Advisors

Tres formas en que la auditoría forense fortalece la integridad institucional

En el entorno actual de cumplimiento de alto riesgo, se espera que las instituciones financieras entreguen más que resultados. Deben demostrar una rendición de cuentas que sea verificable y lista para auditorías. Esto es...more

Foodman CPAs & Advisors

Three Ways Forensic Reporting Builds Institutional Integrity

In today’s high-stakes compliance environment, financial institutions are expected to deliver more than results. They must demonstrate accountability that is both verifiable and audit-ready. This is especially critical for...more

K&L Gates LLP

Key Lessons From the Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

K&L Gates LLP on

On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) published a threat assessment (the Assessment) on compliance with UK sanctions and money laundering law for art market participants (AMPs) and high...more

The Volkov Law Group

Episode 377 -- Refocusing Due Diligence on Cartels and TCOs

The Volkov Law Group on

Could your supply chain be funding cartels without you realizing it? In today’s complex global economy, companies are grappling with a dual challenge - the urgent need to unravel their supply chains and the immediate...more

Secretariat

Taking The Right Approach in Asset Searching and Recovery in 2025

Secretariat on

The tension among regulators between the push for increased transparency and the need to protect individual privacy is always apparent in asset searching exercises. This tension is a global phenomenon, central to the ongoing...more

The Volkov Law Group

Cartel and TCO Due Diligence and Risk Factors (Part II of II)

The Volkov Law Group on

Cartels and TCOs have entrenched themselves in legitimate industry sectors. In recent years, cartels and TCOs have adapted to market changes and new technologies. Many cartels and TCOs are disguising their ownership and...more

Morrison & Foerster LLP

The FTC Gives the Merchant of Record Model a Paddling

The Federal Trade Commission (FTC) recently settled an enforcement action with Paddle.com, a U.K.-based payments company, and its U.S. subsidiary (“Paddle”). The settlement resolves claims against Paddle for violation of the...more

Carey Olsen

Introducing CARF - the OECD's Crypto-Asset Reporting Framework

Carey Olsen on

The recent proliferation of crypto-assets and its uses have transformed the international financial landscape, offering innovative opportunities for payments, investment and Decentralised Finance (DeFi). At the heart of it,...more

Alston & Bird

FATF Updates Grey List of Monitored Jurisdictions

Alston & Bird on

The Financial Action Task Force (FATF) has updated its listings of jurisdictions under increased monitoring (the “grey list”) and high-risk jurisdictions subject to a call for action (the “black list”). Our Investment Funds...more

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

Holland & Knight LLP on

The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...more

Lowenstein Sandler LLP

OFAC Imposes Largest-Ever Penalty on Nonbank Financial Institution for Egregious and Sustained Sanctions Violations—a $216M...

Lowenstein Sandler LLP on

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) announced a historic $215,988,868 civil monetary penalty against GVA Capital Ltd. (GVA), a venture-capital firm registered in the Cayman Islands...more

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

Troutman Pepper Locke on

Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

Gordon Rees Scully Mansukhani

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more

WilmerHale

The New German Government’s Agenda on Compliance

WilmerHale on

On May 5, 2025, the Christian Democratic Union of Germany (CDU) and the Christian Social Union (CSU) entered into a coalition agreement (Coalition Agreement) with the Social Democratic Party of Germany (SPD) (together with...more

K&L Gates LLP

What Legal Services Providers Need to Learn From OFSI's Legal Services Threat Assessment

K&L Gates LLP on

In its first-ever threat assessment of the UK legal sector, the UK’s Office of Financial Sanctions Implementation (OFSI) has raised red flags with regards to suspected sanctions breaches involving UK legal services providers...more

Hogan Lovells

Changes in Beneficial Ownership rules under the new EU Anti-Money Laundering Regulation (EU) 2024/1624

Hogan Lovells on

The adoption of the EU Anti Money Laundering Regulation (EU) 2024/1624 (the “AML Regulation") marks a significant advancement in the European Union's efforts to combat money laundering and terrorist financing. Effective from...more

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