Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Navigating Bank-Fintech Partnerships: Avoiding Common Pitfalls — The Consumer Finance Podcast
Episode 302 -- Matt Stankiewicz on DOJ's Massive Criminal Settlement with Cryptocurrency Exchange Binance and its CEO Changpeng Zhao
Practical Lessons Learned Regarding the Bank Secrecy Act and Anti-Money Laundering for Financial Institutions - The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: A Look at the Treasury Department’s April 2023 Report on Decentralized Finance or “DeFi”
A Discussion with Nacha on Proposed Rulemaking Regarding Fraud - Payments Pros: The Payments Law Podcast
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
Credit Eco To Go Podcast: “You are either in front of the dragon, or behind the dragon”
The New BSA Whistleblower Law: What You Need to Know
FCPA Compliance and Ethics Report-Episode 172-Scott Killingsworth on Personal Liability of CCOs
On February 5, U.S. Attorney General (AG) Pam Bondi issued 14 memoranda to Department of Justice (DOJ) employees framing the DOJ's current policies and enforcement priorities. These shifting enforcement priorities are aligned...more
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
On August 28, 2024, FinCEN Final New Rules were published that address vulnerabilities in the U.S. financial system and are part of an on going effort to combat illicit finance and protect U.S. national security, as well as...more
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule setting forth the circumstances under which beneficial ownership information reported to FinCEN pursuant to the Corporate...more
Due diligence is generally recognized in three levels: Level I, Level II and Level III. Each level is appropriate for a different level of corruption risk. The key is to develop a mechanism to determine the appropriate level...more
In connection with the Biden Administration’s ongoing crackdown on corruption, tax havens, and illicit financing, on December 11, Treasury released a Fact Sheet on its “efforts to address the illicit finance and national...more
How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more
The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement. Last week, Lisa Monaco, DOJ’s...more
Federal prosecutors enjoy flipping through the United States Criminal Code, 18 U.S.C. §§ 1 et seq., to pick out tools to charge defendants. Over the last ten years, DOJ’s reliance on criminal charges in FCPA cases has...more
The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals. ...more
On June 30, 2021, FinCEN announced the first set of government-wide AML/CFT Priorities, as required by the Anti-Money Laundering Act of 2020 ("AML Act"). Consistent with the National Strategy for Combating Terrorist and Other...more
There has been significant movement recently, by both the Biden Administration as well as Congress, to enhance the U.S. government’s ability to tackle corruption. This article provides a summary of those efforts and several...more
The Biden Administration is taking over the reins of government with vigor and focus. The Department of Justice, the Treasury Department, the State Department and the Commerce Department are expected to coordinate closely in...more
On 24 December 2020, the UK and the EU reached a new Trade and Cooperation Agreement. The deal, which came into force on 1 January 2021, has important implications for white collar crime enforcement across Europe, and in...more
(i) a licensing regime for virtual asset trading platforms in Hong Kong, including anti-money laundering obligations; (ii) a two-tier registration regime for dealers in precious metals and stones; and...more
Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more
There are other U.S laws that intersect with the FCPA. A violation of the FCPA may also constitute a violation of the characteristics of another U.S. Law – in this case the Travel Act....more
Law Enforcement Has Been Using GTO Data - First of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering - The U.S. Government Accountability Office (“GAO”) has issued a report on the status and...more
Compliance management has moved from being a nice to have, to an absolute need to have. For many organizations, it is part of business-as-usual (BAU). The scale and scope of compliance frameworks across the world have grown,...more
Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more
First Post in a Two-Post Series on Recent FATF Activity - Members presumably working from home, the Financial Action Task Force (“FATF”) was active last week, first issuing its 3rd Enhanced Follow-up Report & Technical...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
El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas. Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more
A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations. A Financial Institution’s OFAC compliance program is required to...more
On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more