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BSA/AML FATF Anti-Money Laundering

Carlton Fields

Deadline Approaches for RIAs to Adopt AML Programs CIP Requirements Remain in Limbo

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On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). For...more

Ballard Spahr LLP

FATF Re-Rates United States as “Largely Compliant” with Beneficial Ownership Recommendation

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The Financial Action Task Force (“FATF”) has re-rated the U.S. as “largely compliant” with FATF’s Recommendation 24, which pertains to transparency related to beneficial ownership of legal persons. Specifically, FATF...more

Ballard Spahr LLP

The Basel AML Index: Forfeiture, Non-Profits, Crypto, and More. A Guest Blog.

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Today we are very pleased to welcome, once again, guest blogger Dr. Kateryna Boguslavska of the Basel Institute on Governance (“Basel Institute”), who will discuss the Basel Institute’s release of the 12th annual Public...more

StoneTurn

3 Key Takeaways from FATF’s Recent Mutual Evaluations Report

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The Financial Action Task Force (“FATF”) recently released its Report on the State of Effectiveness and Compliance with the FATF Standards (“Report”). The Report contains the results of its 4th Round of Mutual Evaluations...more

K2 Integrity

FATF Plenary Outcomes: October 21-23, 2020

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Beginning on October 21, 2020, the Financial Action Task Force (“FATF”) held its three-day Plenary meeting virtually. It was the first Plenary of Germany’s two-year Presidency. As part of the Plenary outcomes, the FATF...more

Ballard Spahr LLP

Joint Statement Clarifies Due Diligence Expectations for Politically Exposed Persons

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Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more

Foodman CPAs & Advisors

El FATF identifica las Amenazas de Lavado de Dinero derivadas de la Crisis del Covid-19

En mayo del 2020, el FATF (GAFI) publicó nuevas amenazas y vulnerabilidades de lavado de dinero y financiamiento del terrorismo derivadas de la crisis COVID-19. El documento destaca cómo el fraude, el cibercrimen, la mala...more

Foodman CPAs & Advisors

The FATF identifies Money Laundering Threats arising from the Covid-19 Crisis

On May, 2020, the FATF published new money laundering and terrorist financing threats and vulnerabilities arising from the COVID-19 crisis.  The document highlights how fraud, cybercrime, misdirection of government funding...more

Ballard Spahr LLP

Money Laundering and the Illegal Wildlife Trade

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The Financial Action Task Force (“FATF”) just released an important report entitled Money Laundering and the Illegal Wildlife Trade (the “Report”).  The lengthy and detailed Report makes clear that the IWT is pernicious...more

Foodman CPAs & Advisors

How are Financial Institutions identifying and managing their PEP relationships?

With respect to customers, Financial Institutions are required to have processes in place for identifying Politically Exposed Persons – known as “PEPs”.  ...more

Orrick - On the Chain

FinCEN Sends Message to the Virtual Currency Industry: The Travel Rule Applies to You, Too

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FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more

Ballard Spahr LLP

FATF Issues Paper on COVID-19 Enhanced AML and Fraud Risks

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On May 4, the Financial Action Task Force (“FATF”) issued a paper entitled “Covid-19-Related Money Laundering and Terrorist Financing – Risk and Policy Responses (“Paper”). ...more

K2 Integrity

Beneficial Ownership: Current Challenges Met with Opportunity

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Beneficial ownership is a topic which presents significant challenges to compliance officers charged with untangling a web of ownership interests that span numerous international jurisdictions and ownership structures. ...more

Ballard Spahr LLP

Financial Action Task Force Grades America’s AML Compliance

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Second Post in a Two-Post Series on Recent FATF Activity - As we just blogged, the Financial Action Task Force (“FATF”) issued a statement from its President on COVID-19 and measures to combat illicit financing during the...more

Ballard Spahr LLP

Financial Action Task Force Update: Statement on COVID-19’s Implications for AML Programs

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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

Foodman CPAs & Advisors

The U.S.A Continues to be AML/BSA “Vulnerable”

The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/CFT threats. ...more

Ballard Spahr LLP

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

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In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

Ballard Spahr LLP

Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key...

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First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more

Ballard Spahr LLP

Trade-Based Money Laundering: GAO Report Stresses Enforcement Challenges

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On January 29, 2020, the U.S. Government Accountability Office (GAO) publicly released the results of a study which the GAO conducted on trade-based money laundering, or TBML, entitled “Countering Illicit Finance and Trade:...more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

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On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

Ballard Spahr LLP

FATF Issues Best Practices Guidance on Beneficial Ownership Information

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As we blogged yesterday, the issue of the beneficial ownership of entities and the potentially pernicious role of shell companies in perpetuating money laundering is the primary anti-money laundering (“AML”) concern across...more

Ballard Spahr LLP

Shell Company Update: Congress and FATF Target Beneficial Ownership

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U.S. House Passes Corporate Transparency Act; FATF Issues Guidance on Identifying Entities’ Beneficial Owners - First Post in a Two-Post Series on Beneficial Ownership - As we often blog, the issue of the beneficial...more

Ballard Spahr LLP

What the Basel AML Index Reveals About Global Money Laundering Risks

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Established in 2003, the Basel Institute is a not-for-profit Swiss foundation dedicated to working with public and private partners around the world to prevent and combat corruption, and is an Associated Institute of the...more

Perkins Coie

Blockchain Week in Review - December 2018

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U.S. Developments - SEC Remarks on International Virtual Currency Enforcement - On December 5, 2018, Steven Peikin, Co-Director of the Division of Enforcement at the U.S. Securities and Exchange Commission (“SEC”), gave a...more

A&O Shearman

Financial Action Task Force Clarifies Virtual Asset Regulation

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The Financial Action Task Force has published the outcomes of its plenary on October 17-19, 2018. The FATF considered key issues such as the operations and streamlining of the FATF, major and other strategic initiatives and...more

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