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 July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more
The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more
Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more
The crypto industry is evolving rapidly, and regulatory enforcement is keeping pace. Businesses engaged in crypto transactions, custody, lending, trading, or payments must navigate know your customer (KYC) and anti-money...more
Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more
On August 1, 2024, Deputy Attorney General Lisa Monaco announced the launch of DOJ’s Corporate Whistleblower Awards Pilot Program (Pilot Program). The Pilot Program, previewed by Monaco in March 2024, provides another avenue...more
In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more
The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more
On July 1, 2024, the Supreme Court issued its opinion in Corner Post, Inc. v Board of Governors of the Federal Reserve System in which the Court determined when a Section 702 claim under the Administrative Procedure Act (APA)...more
A press release was recently issued describing a significant joint proposal by the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The proposal...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
Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more
On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more
Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...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 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more
On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more
On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more
On January 12, South Dakota’s Division of Banking issued a mandate setting March 31, 2024 as the deadline for all South Dakota licensed money lenders and non-residential mortgage brokers to comply with their Bank Secrecy...more
On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently announced a Notice of Proposed Rulemaking (NPRM) aimed at keeping bad actors from exploiting the U.S. financial system and assets...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
On November 21, the U.S. Department of Justice (DOJ) unsealed its criminal indictment against Binance.com (Binance), the world’s largest cryptocurrency exchange, and its CEO, Changpeng “CZ” Zhao (CZ). The indictment against...more
Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more