News & Analysis as of

Due Diligence AML/CFT Anti-Money Laundering

A&O Shearman

Wolfsberg Group issues statement on the RBA for financial crime risk management

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The Wolfsberg Group (the Group) has released a statement reaffirming its commitment to the risk-based approach (RBA) for financial crime risk management. Further to its 2006 RBA guidance, and in line with the Financial Action...more

K&L Gates LLP

Key Lessons: The Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

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On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) released a Threat Assessment (the Assessment) targeting Art Market Participants (AMPs) and High-Value Dealers (HVDs). This follows new rules from 14...more

K&L Gates LLP

Key Lessons From the Latest UK Office for Financial Sanctions Implementation Art Market Participants and High Value Dealers Threat...

K&L Gates LLP on

On 18 June 2025, the UK Office for Financial Sanctions Implementation (OFSI) published a threat assessment (the Assessment) on compliance with UK sanctions and money laundering law for art market participants (AMPs) and high...more

Goodwin

AML/CTF Asset Due Diligence Obligations: CSSF Provides Clarifications in an initial Q&A

Goodwin on

On 13 December 2024, the Commission de Surveillance du Secteur Financier (CSSF) published the first FAQ to assist professionals in the investment sector supervised, authorised, or registered by the CSSF in complying with...more

ArentFox Schiff

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

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On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

Ballard Spahr LLP

Federal Banking Agencies Issue Guide to Third-Party Risk Management Practices for Community Banks

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On May 3, 2024, the Board of Governors of the Federal Reserve System (the “Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), and the Office of the Comptroller of the Currency (“OCC”) jointly released the...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

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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

Akin Gump Strauss Hauer & Feld LLP

FinCEN Proposes New Rule to Expand Anti-Money Laundering Requirements for Investment Advisers

Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more

Walkers

Removal of the Cayman Islands from the EU AML List and UK AML List

Walkers on

Following the removal of the Cayman Islands from the Financial Action Task Force's list of "jurisdictions under increased monitoring" in October 2023, on 12 December 2023, the European Commission adopted the Commission...more

K2 Integrity

The Challenge of Transparency in Preventing Financial Crime: Navigating Financial Integrity in a Changing Risk Landscape

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The landscape of financial crimes is constantly evolving, and the concept of transparency is being fundamentally challenged. A dynamic, innovative approach is imperative to preserve and shape the future of financial...more

Ballard Spahr LLP

SEC Exam Priorities Target AML

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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

Walkers

Updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation Financing in the...

Walkers on

Following industry consultation, on 30 August 2023 the Cayman Islands Monetary Authority ("CIMA") issued updated Guidance Notes on the Prevention and Detection of Money Laundering, Terrorist Financing and Proliferation...more

Troutman Pepper Locke

FFIEC Updates Bank Secrecy Act/Anti-Money Laundering Examination Manual

Troutman Pepper Locke on

On August 2, the Federal Financial Institutions Examination Council (FFIEC) announced updates to certain sections and examination procedures in the FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual (Manual). The...more

Walkers

What can we learn from recent enforcement actions in the Cayman Islands?

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Walkers' regulatory partners Lucy Frew and Ian Mason consider the learning points for financial services providers (FSPs) from recent enforcement actions by Cayman regulatory bodies. While financial services and related...more

Walkers

Central Bank of Ireland - Anti-Money Laundering Bulletin for the Funds Sector

Walkers on

Having recently conducted a number of anti-money laundering, counter financing of terrorism and financial sanctions (“AML/CFT/FS”) supervisory engagements with Funds and Fund Management Companies (“Firms”), the Central Bank...more

K2 Integrity

Sanctions Against Russia: Understanding the Evolving Picture and How to Respond

K2 Integrity on

...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more

Foodman CPAs & Advisors

¿Hay Ayuda en el Camino para los “Derisked”?

El aumento de los costos de cumplimiento, las estructuras de clientes corporativos difíciles de entender, las multas y sanciones, el cambio de la responsabilidad corporativa a la responsabilidad individual y las...more

A&O Shearman

Australia moves – incrementally – towards AML/CTF compliance

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Australia has implemented “Phase 1.5” in its anti-money laundering and counter-terrorism reforms. However, Australia’s long-awaited and much-debated “second tranche” of reforms remains out of grasp. ...more

Ballard Spahr LLP

Westpac’s Alleged AML Failures Back in the News

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Internal Investigation Report Stresses Lack of Intentional Misconduct – But the Investigation May Broaden - Westpac Banking Corporation (“Westpac”), Australia’s second largest retail bank, has been besieged by serious...more

K2 Integrity

FATF Calls for Reimposition of Countermeasures on Iran

K2 Integrity on

The Financial Action Task Force (FATF) on February 21, 2020, reintroduced its call for countries to impose countermeasures to protect themselves from illicit finance threats emanating from Iran. The call for countermeasures...more

BCLP

Letting agents: anti-money laundering requirements

BCLP on

On 10 January 2020, The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 came into force. As a result, letting agents are now supervised by HMRC for anti-money laundering and counter-terrorist financing...more

Hogan Lovells

UK FCA becomes AML/CFT crypto supervisor

Hogan Lovells on

The UK Financial Conduct Authority (FCA) has become the anti-money laundering and countering the financing of terrorism (AML/CFT) supervisor for some types of cryptoasset businesses. These will need to meet certain...more

White & Case LLP

The French Financial Markets Authority released its new guidelines on AML/CFT

White & Case LLP on

The French Financial Markets Authority ("AMF") has just carried out a complete overhaul of its doctrine on Anti-Money Laundering/Combating the Financing of Terrorism ("AML/CFT") and published its new guidelines setting out...more

Orrick, Herrington & Sutcliffe LLP

The implementation of the Fifth Anti Money Laundering Directive in German Law – Tighten the tight?

In the course of the “Panama Paper” scandal, Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing – known as 4. Anti-Money Laundering...more

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