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 June 27, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order (Order) allowing banks,[1] and their subsidiaries, subject to the jurisdiction of the Office of the Comptroller...more
• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more
On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing...more
Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs - On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more
Non-fungible tokens (NFTs) often involve two areas with known money laundering and terrorist financing risks: cryptocurrencies and high-value assets, like art. As detailed below, the U.S. Treasury Department’s Financial...more
The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”) has made clear that businesses engaging in certain activities involving virtual currencies are subject to registration,...more
By now, most everyone knows that ransomware is software that infects your computer system, makes your data irretrievable and usually breaks things along the way. To unlock your system, the bad guys (or girls) demand you pay a...more
In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more
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
Leaders of FinCEN, CFTC and SEC Attempt an Intricate Dance of Competing Oversight of Virtual Currency - On October 11, the leaders of the Financial Crimes Enforcement Network (“FinCEN”), the Commodity Futures Trading...more
Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...more
On August 21, 2019, FinCEN issued an advisory (the “Advisory”) alerting financial institutions to various financial schemes and mechanisms employed by fentanyl and synthetic opioid traffickers to facilitate the illegal...more
Smaller banks and money services businesses should expand their AML compliance to mitigate human trafficking corporate liability. Aside from the Bank Secrecy Act, federal law creates corporate liability for financial...more
Earlier this week, the Eleventh Circuit affirmed, in an unpublished opinion, that Coinbase Inc., an online platform used for buying, selling, transferring, and storing digital currency, could not compel arbitration on a...more
Sometimes risk analysis can result in paralysis. Finding your risk tolerance and applying it to specific situations requires a nuanced approach. I am always wary of anyone who tells me categorical rules – e.g. we do not...more