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
The U.S. Securities and Exchange Commission's recent anti-money laundering enforcement actions reflect a number of trends and developments, but one positive and one negative trend stand out. Originally published in Law360...more
In the possible final stage of the Alpine Securities saga, Judge Clark Waddopous of the United States District Court for the District of Utah issued an opinion granting the Securities and Exchange Commission’s (“SEC”) motion...more
On October 21, 2024, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) released its annual Examination Priorities for fiscal year 2025 (the Report). The Report identifies certain...more
On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more
On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more
The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more
On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more
The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more
As reported in more detail on our Regulatory Oversight blog, the Securities and Exchange Commission’s Division of Examinations recently released its 2024 Examination Priorities report. The report underscores the SEC’s intent...more
On October 16, the Securities and Exchange Commission’s Division of Examinations (the Division) released its 2024 Examination Priorities report. The report highlights that future examinations will focus on “risk areas...more
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
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) adopted amendments to modernize filing fee disclosure and payment methods; the Financial Industry Regulatory Authority (FINRA) announced an examination of...more
1. AML Laws - Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more
The Situation: The Securities and Exchange Commission’s Division of Examinations ("EXAMS") released a Risk Alert on March 29, 2021, reminding broker-dealers of their obligation to comply with anti-money laundering ("AML")...more
On October 11, 2019, the leaders of the US Securities and Exchange Commission (SEC), the US Commodity Futures Trading Commission (CFTC), and the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a...more
While many of us were winding down the year focused on the December holidays, the U.S. Department of Justice, the SEC, FINRA, and FinCEN were busy delivering a flurry of messages to the broker-dealer industry about AML...more
For the first time, a broker-dealer, Central States Capital Markets, LLC (Central States), has been prosecuted for violating the Bank Secrecy Act (BSA). ...more
On June 5, the SEC filed suit against Salt Lake City-based Alpine Securities, Corp. (“Alpine”). The complaint, filed in the Southern District of New York, alleges that the broker-dealer ran afoul of AML rules by “routinely...more
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
On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more
On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed rulemaking that would require registered investment advisers, including certain hedge funds and asset managers, to establish anti-money laundering...more
The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more
On Tuesday, the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would require SEC-registered investment advisers, including private equity and hedge funds, to comply...more