News & Analysis as of

Department of Justice (DOJ) BSA/AML Financial Institutions

Morgan Lewis

Financial Institutions Face Investigations and Possible Referral to DOJ Based on Past ‘Debanking’ Practices

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An executive order signed by the US president on August 7, 2025, titled Guaranteeing Fair Banking for All Americans, seeks to prohibit financial institutions from engaging in “debanking” practices, such as denying services or...more

DLA Piper

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

DLA Piper on

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

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

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

The Volkov Law Group

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

The Volkov Law Group on

“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

Lowenstein Sandler LLP

TD Bank to Pay Historic $3 Billion Over AML Compliance Violations

Lowenstein Sandler LLP on

On October 10, 2024, multiple U.S. federal and state agencies cumulatively fined a number of US based Toronto Dominion Bank subsidiaries (collectively, TD Bank or the Bank) more than $3 billion after finding that TD Bank...more

The Volkov Law Group

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

The Volkov Law Group on

In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more

Ballard Spahr LLP

Nevada Gaming Control Board Alleges Casino AML Failures Based on Wagering of Customers Involved in Illegal Bookmaking

Ballard Spahr LLP on

The Nevada Gaming Control Board (“Board”) recently filed a complaint (“Complaint”) against Resorts World Las Vegas casino (“Resorts World”), alleging that, despite repeated red flags, Resorts World’s Anti-Money Laundering...more

Ballard Spahr LLP

DOJ Unveils Corporate Whistleblower Awards Pilot Program – With Implications for Financial Institutions and AML/CFT Compliance...

Ballard Spahr LLP on

On August 1, 2024, the Department of Justice launched its Corporate Whistleblower Awards Pilot Program (the “Pilot Program”). Under this 3-year initiative managed by DOJ’s Criminal Division, a whistleblower may be eligible...more

Ballard Spahr LLP

FinCEN Issues Supplemental Advisory on Fentanyl Distribution and Growing Role of Transnational Criminal Organizations

Ballard Spahr LLP on

On June 20, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplemental advisory to alert U.S. financial institutions about emerging trends in the illicit fentanyl supply chain. The supplemental advisory...more

Ballard Spahr LLP

EDNY Upholds Money Laundering Charge Against Defense Attack Under Ciminelli

Ballard Spahr LLP on

In United States v. An, et al., 22-cr-640 (KAM) (E.D.N.Y. May 7, 2024), the Eastern District of New York recently addressed and rejected an argument by defendants that Ciminelli v. United States required dismissal of money...more

Jones Day

OCC Proposal and Policy Statement on Bank Mergers Could Freeze the Banking Industry in Place

Jones Day on

The Situation: On January 29, 2024, the Office of the Comptroller of the Currency ("OCC") requested comment on a proposed rule updating its bank merger rules and incorporating a policy statement (the "Proposal") on agency...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Financial Institution Officers

Ballard Spahr LLP on

The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Casinos

Ballard Spahr LLP on

The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Ballard Spahr LLP

SDNY Court Finds Broad Fed Powers Over Master Accounts in Puerto Rican Bank Case Involving AML Concerns

Ballard Spahr LLP on

The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of New York, denying a...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

Ballard Spahr LLP on

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

White & Case LLP

Bitzlato Founder Charged With Facilitating Money Laundering of More than $700 Million in Dark Web Funds

White & Case LLP on

Anatoly Legkodymov, Russian founder of Hong Kong-registered cryptocurrency exchange Bitzlato Limited ("Bitzlato"), was arrested on January 17 based on an Amended Complaint filed by the Department of Justice ("DOJ") charging...more

Venable LLP

Marijuana Banking in 2022: Lessons Learned and Best Practices

Venable LLP on

​​​​​​​As we pass the halfway mark of 2022, it's a good time to reflect on what has happened, or not happened, with respect to the legal framework for the provision of financial services to marijuana-related businesses...more

Holland & Knight LLP

Red Flag Refresher: Broker-Dealers and the Importance of Strong AML Compliance

Holland & Knight LLP on

The SEC continues to focus a portion of its enforcement attention on registrants' obligations with regard to anti-money laundering (AML) compliance and transaction monitoring. In this post, we provide a refresher on the...more

BakerHostetler

$3.6 Billion Reasons to Up Cryptocurrency Compliance: FBI Cracking Down on Crypto Criminals

BakerHostetler on

Key Takeaways - ..Banks and cryptocurrency exchanges need to update their BSA programs to account for the unique aspects of cryptocurrencies, detect and report related suspicious activity, and minimize the risk of...more

Morrison & Foerster LLP

Financial Services Report - Winter 2021

Morrison & Foerster LLP on

Welcome to the Financial Services Report, holiday style! Banks and non-banks alike started early this year with additions and changes to their regulator stockings. The Senate confirmed Rohit Chopra as the new CFPB Director....more

Perkins Coie

AMLA 2020 Series Part 2: New Bank Secrecy Act Whistleblower Provisions

Perkins Coie on

On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more

Ballard Spahr LLP

CFTC and DOJ Charge BitMEX and Executives With Illegally Trading in Digital Assets and Ignoring BSA/AML Requirements

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Incorporating in the Seychelles but Allegedly Operating in the U.S. Spells Trouble for Company and its Founders - The Bitcoin Mercantile Exchange, or BitMEX, is a large and well-known online trading platform dealing in...more

Ballard Spahr LLP

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

Ballard Spahr LLP on

Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

Ballard Spahr LLP

GAO Publishes Report on Effectiveness of Real Estate GTOs Issued by FinCEN

Ballard Spahr LLP on

Law Enforcement Has Been Using GTO Data - First of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering - The U.S. Government Accountability Office (“GAO”) has issued a report on the status and...more

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