News & Analysis as of

Digital Assets Customer Due Diligence (CDD)

Sheppard Mullin Richter & Hampton LLP

OCC Terminates 2022 Consent Order Against National Bank

On August 18, the OCC terminated its 2022 consent order against a national bank. The order was issued under the Bank Secrecy Act and related anti-money laundering regulations, and required the bank to implement corrective...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Walkers

Global Legal Insights Fintech 2023: Cayman Islands

Walkers on

Approaches and developments - The Cayman Islands has long been a leading offshore jurisdiction for investment funds, as well as a significant global financial centre overall. It is therefore not surprising that, reflecting...more

Orrick, Herrington & Sutcliffe LLP

Crypto platform reaches $100 million settlement to resolve alleged compliance failures

On January 4, NYDFS issued a consent order against a cryptocurrency trading platform for engaging in alleged violations of New York virtual currency, anti-money laundering, transaction monitoring, and cybersecurity...more

Ballard Spahr LLP

FATF Identifies Red Flags for Virtual Assets and Money Laundering

Ballard Spahr LLP on

The Financial Action Task Force (FATF) recently published a report titled Virtual Assets: Red Flag Indicators of Money Laundering and Terrorist Financing. The report discusses a number of red flag indicators of suspicious...more

Holland & Knight LLP

Treasury Releases 2020 National Strategy for Combating Terrorist and Other Illicit Financing

Holland & Knight LLP on

The 2020 National Strategy for Combating Terrorist and Other Illicit Financing was issued earlier this month by the U.S. Department of the Treasury. Prepared in consultation with regulators and law enforcement, including the...more

A&O Shearman

Financial Action Task Force Consults on Digital Identity in Customer Due Diligence Guidance

A&O Shearman on

The Financial Action Task Force is seeking feedback from private sector stakeholders on its draft guidance on the use of digital identity systems in customer due diligence. The guidance will supplement Recommendation 10 of...more

Foodman CPAs & Advisors

The Financial Action Task Force and Virtual Assets

The FATF (FATF) is an inter-governmental body with 38 members that sets standards and promotes the implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and threats...more

White & Case LLP

Cryptoassets and Open Source Software: UK proposes gold-plating transposition of the EU Fifth Money Laundering Directive

White & Case LLP on

Currently, cryptoasset exchanges and wallet providers are not generally required (depending on their business model) to identify their customers, monitor transactions or report suspicious activity. On 15 April HM Treasury...more

A&O Shearman

FINRA Issues 2019 Annual Risk Monitoring and Examination Priorities Letter, Highlighting Potential Areas Of Enforcement Risk

A&O Shearman on

On January 22, 2019, the Financial Industry Regulatory Authority (“FINRA”) issued its annual letter describing its current risk monitoring and examination priorities. See FINRA, Risk Monitoring and Examination Priorities...more

Orrick, Herrington & Sutcliffe LLP

SEC and FINRA's Annual Rites – Announcing Their Examination Priorities

On January 22, 2019, FINRA published its 2019 Risk Monitoring and Examination Priorities Letter. Released several weeks later than usual, FINRA’s letter follows the December 10, 2018 publication of the 2019 Examination...more

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