News & Analysis as of

Beneficial Owner Customer Due Diligence (CDD) Risk Management

Constangy, Brooks, Smith & Prophete, LLP

Wire Fraud: Should banks CYA by tightening up on KYC?

After a long weekend, Finance Manager Joe sits at his desk to read his emails. One of the emails is from a trusted vendor with whom the Joe communicates on a regular basis, regarding an unpaid invoice that is due immediately....more

Troutman Pepper Locke

OCC’s Semiannual Report Highlights Emerging Risk of AI in Banking

Troutman Pepper Locke on

On December 7, the Office of the Comptroller of the Currency (OCC) published the fall edition of its Semiannual Risk Perspective, which discusses key issues facing banks. From the OCC’s perspective, the overall strength of...more

The Volkov Law Group

Addressing Beneficial Ownership Requirements in Your Compliance Program (Part I of IV)

The Volkov Law Group on

We repeatedly hear about the importance of beneficial ownership, and the requirement that companies confirm beneficial ownership of its third-parties, vendors and suppliers.  At the same time, there is increasing pressure...more

Ballard Spahr LLP

OCC Semiannual Risk Perspective Highlights Cybersecurity, Fraud, Money Laundering Concerns

Ballard Spahr LLP on

Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses up-to-date data to identify risks to U.S. banks and measure their compliance...more

Ballard Spahr LLP

OCC Report: Same Threats, Different Season

Ballard Spahr LLP on

OCC Identifies AML/BSA and Cyber Threats as Elevated Risks Facing Banks - Last week, the Office of the Comptroller of the Currency (“OCC”) published the Spring 2018 Semiannual Risk Perspective (the “Report”), which uses...more

Ballard Spahr LLP

Congress Proposes National Directory of Beneficial Owners of Legal Entities

Ballard Spahr LLP on

Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), currently in committee in the Senate.  The CTIFA proposes the most substantial overhaul to the Bank Secrecy Act (“BSA”) since...more

The Volkov Law Group

Incorporating AML Compliance Into a Compliance Program (Part III of III)

The Volkov Law Group on

Global companies should implement an AML program and KYC practices that follow the general outline for best practices, though it does not need to be as rigorous as a financial institution. For most companies, AML risks can...more

K2 Integrity

FinCEN’s Beneficial Ownership Rule and Increased AML Burden

K2 Integrity on

Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more

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