News & Analysis as of

BSA/AML Money Laundering

Troutman Pepper Locke

OCC Patriot Bank Order Spotlights AML Issues For Managers

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On Jan. 14, Patriot Bank, based in Stamford, Connecticut, entered into an agreement with the Office of the Comptroller of the Currency to address and rectify several alleged unsafe or unsound practices and violations of law....more

Morrison & Foerster LLP

No Full TIN, No Problem: FinCEN Approves of TIN Verification Through a Third Party

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

Troutman Pepper Locke

Recent SEC AML Enforcement Actions’ Impact on Compliance Efforts in the Cannabis Sector

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Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more

Gordon Rees Scully Mansukhani

Recent SEC AML Enforcement Against Securities Firms Engaged in Cannabis Sector

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

Ballard Spahr LLP

FinCEN Issues Southwest Border Geographic Targeting Order Aimed to Combat Mexican-based Drug Cartels

Ballard Spahr LLP on

We have written previously about the new administration’s significant shifts in its approach to criminal enforcement and prosecution of money laundering cases. Specifically, we wrote about shifts at the U.S. Department of...more

Holland & Knight LLP

FinCEN Geographic Targeting Order Imposes Additional Recordkeeping and Reporting Requirements

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more

Carlton Fields

Crypto Business Compliance: U.S. Licensing and Regulations

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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

Troutman Pepper Locke

Key Considerations After DOJ Announces Shifting Enforcement Priorities

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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

Ballard Spahr LLP

Brink’s Global Services Faces Major Fines: The DOJ and FinCEN Crackdown on AML Violations

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Brinks Global Services USA (“BGS USA”), a global leader in secure logistics, found itself at the center of a significant regulatory investigation due to its failure to meet anti-money laundering (“AML”) obligations....more

DLA Piper

Recent Settlement Demonstrates DOJ’s Focus on Foreign Entities Misrepresenting Anti-Money Laundering Compliance

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The US Department of Justice (DOJ) has announced that Wall Street Exchange (WSE), a Dubai-based money exchange service provider, entered into a non-prosecution agreement (NPA) and agreed to pay more than $9.2 million to...more

McDermott Will & Emery

The High Cost of Noncompliance: Making Sense of BitMEX’s $100 Million AML Penalty

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On January 15, 2025, BitMEX, a Seychelles-registered crypto exchange, was fined $100 million in connection with a previously entered guilty plea to criminal violations of US anti-money laundering (AML) laws. The penalty...more

Bradley Arant Boult Cummings LLP

Community Banks and BSA/AML Compliance: The OCC’s Consent Order with Clear Fork Bank Proves Regulators Aren’t Only Focused on...

On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s...more

Bradley Arant Boult Cummings LLP

$3B TD Bank AML Settlement Is A Wake-Up Call For All Banks

On Oct. 10, Attorney General Merrick Garland announced that TD Bank pled guilty to conspiracy to commit money laundering and agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice's...more

Ballard Spahr LLP

Another Chapter in the Alpine Securities Saga: District Court Grants Motion to Dismiss Complaint Challenging AML Enforcement...

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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

Ballard Spahr LLP

FinCEN Issues Alert on Countering Financing of Hizballah and Terrorist Activities

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On October 23rd, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplementary alert regarding countering financing of the U.S.-designated foreign terrorist organization Hizballah (the “Alert”). In May 2024,...more

Baker Botts L.L.P.

The Corporate Transparency Act: January 1, 2025 Deadline Approaching Fast

Baker Botts L.L.P. on

The Corporate Transparency Act (the “CTA”) took effect in the United States on January 1, 2024, resulting in significant new beneficial ownership reporting requirements. These requirements have a sweeping effect, as many...more

The Volkov Law Group

Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations

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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

Ballard Spahr LLP

FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML Program

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The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”).  The Consent Order describes Lake...more

Thomas Fox - Compliance Evangelist

TD Bank, Part 6 – Caremark Claims – The Board of Directors

Today, I continue my exploration of the TD Bank AML/BSA enforcement action through two of the most significant cases regarding Boards of Directors and corporate compliance: the Caremark and Stone v. Ritter decisions. The...more

Ballard Spahr LLP

Bank Policy Institute Critiques Notice of Proposed Rulemaking to Modernize AML/CFT Programs

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The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

The Volkov Law Group

TD Bank’s Rotten Corporate Culture — From its Store-Level Operations to its Board’s Audit Committee (Part IV of IV)

The Volkov Law Group on

TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 4- Watergate, Actual Knowledge and Conscious Indifference

Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 3 – Lessons Learned for Compliance

We continue our exploration of the resolution of the AML/BSA enforcement action involving the TD Bank US (the Bank) wholly owned by the TD Bank Group, a publicly traded (NYSE: TD) international banking and financial services...more

The Volkov Law Group

TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV)

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“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors,...more

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