News & Analysis as of

Bank Secrecy Act Department of Justice (DOJ) Financial Crimes

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
Lowenstein Sandler LLP

First Terrorism Indictments Announced Over Drug Cartel Support

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Last Friday, the U.S. Department of Justice (DOJ) unsealed its first indictment against a foreign national for providing material support to a Mexican drug cartel that the current administration recently designated a foreign...more

Rivkin Radler LLP

The Status of the Corporate Transparency Act – It’s Not Clear

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Few would argue that the federal government does not have a legitimate interest in preventing, detecting, and punishing tax fraud, money laundering, and other financial crimes. Likewise, I imagine few would disagree with the...more

The Volkov Law Group

Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations

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How does a respected financial institution turn into a criminal operation? In this episode of Corruption, Crime, and Compliance, host Michael Volkov dives into the record-breaking $3 billion settlement between TD Bank and the...more

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

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On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

Buchalter

Historic AML Prosecution, Previously Led by Shareholder Daniel Silva: Wynn Las Vegas Agrees to $130M Penalty in Largest-Ever...

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On September 6, 2024, Wynn Las Vegas (“Wynn LV”) agreed to forfeit over $130 million to resolve a criminal investigation into the gaming giant’s suspected violated federal anti-money laundering (“AML”) laws. Daniel Silva, a...more

Ballard Spahr LLP

Nevada Gaming Control Board Alleges Casino AML Failures Based on Wagering of Customers Involved in Illegal Bookmaking

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The Nevada Gaming Control Board (“Board”) recently filed a complaint (“Complaint”) against Resorts World Las Vegas casino (“Resorts World”), alleging that, despite repeated red flags, Resorts World’s Anti-Money Laundering...more

Ballard Spahr LLP

FinCEN Issues Supplemental Advisory on Fentanyl Distribution and Growing Role of Transnational Criminal Organizations

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On June 20, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplemental advisory to alert U.S. financial institutions about emerging trends in the illicit fentanyl supply chain. The supplemental advisory...more

Ballard Spahr LLP

EDNY Upholds Money Laundering Charge Against Defense Attack Under Ciminelli

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In United States v. An, et al., 22-cr-640 (KAM) (E.D.N.Y. May 7, 2024), the Eastern District of New York recently addressed and rejected an argument by defendants that Ciminelli v. United States required dismissal of money...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Financial Institution Officers

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The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Ballard Spahr LLP

SDNY Court Finds Broad Fed Powers Over Master Accounts in Puerto Rican Bank Case Involving AML Concerns

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The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of New York, denying a...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

McGlinchey Stafford

Marijuana & Banking: What’s the Hold Up? Part 2 – Compliance Challenges

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For financial institutions who engage in marijuana-related banking services, the primary compliance challenge remains the disconnect between federal and state law, as it is still illegal to manufacture, distribute, or...more

Orrick, Herrington & Sutcliffe LLP

Luetkemeyer accuses DOJ of incomplete BSA/AML data

On February 1, Representative Blaine Luetkemeyer (R-MO) sent a letter to Attorney General Merrick Garland asking for an explanation as to why the DOJ has not complied with a provision in the 2021 National Defense...more

Blank Rome LLP

The Dawn of a New Day: Expansive Law Signals Heightened AML Enforcement

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On January 1, 2021, the Senate voted to override the president’s veto and to enact the National Defense Authorization Act for Fiscal Year 2021 (the “NDAA”). Incorporated into the NDAA, the Anti-Money Laundering Act (“AMLA”)...more

Proskauer - The Capital Commitment

FinCEN Explains What Guides Its Enforcement Decisions

On August 18, 2020, the Financial Crimes Enforcement Network (FinCEN), which is the primary regulator and administrator of the Bank Secrecy Act (BSA), issued a statement on enforcement of the BSA. The requirements of the BSA...more

Orrick, Herrington & Sutcliffe LLP

Treasury Request for Public Input on Expanding Access to Credit through Online Marketplace Lending

On July 20, the Department of the Treasury published a Notice and Request for Information (“RFI”) seeking comment on various aspects of online marketplace lending, including – - the business models and products offered...more

The Volkov Law Group

Revisiting The Corporate Top-10 FCPA Enforcement Actions

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We all like organized lists. Short and sweet is easier to understand and ignore nuances. Even in our FCPA world, we track settlements by a top-10 lost. The concept of a top-10 predated David Letterman’s top-10 lists, and...more

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