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Due Diligence Bank Secrecy Act

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

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The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...more

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

K2 Integrity

Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now?

K2 Integrity on

On 15 January 2025, K2 Integrity hosted a webinar that featured Justina Rousseau, senior managing director at K2 Integrity; Aseel Rabie, counsel at Debevoise & Plimpton LLP; and Sarah Runge, executive managing director at K2...more

ArentFox Schiff

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

ArentFox Schiff on

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

NYDFS Imposes $35 Million Fine on Nordea Bank for Alleged AML Failures Following Panama Papers Revelations

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On August 27, 2024, the New York State Department of Financial Services (“NYDFS”) announced a consent order involving a $35 million settlement with Nordea Bank Abp (“Nordea”) for alleged significant failures related to...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

Holland & Knight LLP on

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

Ballard Spahr LLP

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

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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

K2 Integrity

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

K2 Integrity on

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

Troutman Pepper Locke

Amici Tell Fourth Circuit that District Court Ruling Imperils Funds Transfer Laws

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On October 17, the Clearing House Association, LLC (Association) and National Automated Clearing House Association (Nacha) joined forces to submit an amicus brief in support of a credit union held liable by a district court...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

Orrick, Herrington & Sutcliffe LLP

FinCEN alert covers potential CRE investments by sanctioned Russians

On January 25, the Financial Crimes Enforcement Network (FinCEN) issued an alert to financial institutions on potential investments in the U.S. commercial real estate sector by sanctioned Russian elites, oligarchs, their...more

Harris Beach Murtha PLLC

New York Sends Clear Message Crypto Exchanges and Banks Must Meet AML Obligations

New York’s Department of Financial Services (“DFS”) recently announced a $100 million settlement with Coinbase, Inc., one of the world’s largest cryptocurrency exchanges, for Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”)...more

Guidepost Solutions LLC

Enhanced Due Diligence on Potential Clients is Increasing in Importance for Law Firms

Regulatory trends and high-profile investigations suggest that law firms should conduct enhanced due diligence background checks on all potential clients as part of standard risk management and compliance protocols.   ...more

American Conference Institute (ACI)

[Event] Canadian Forum on Global Economic Sanctions - September 22nd - 23rd, Toronto, ON, Canada

The Canadian Institute’s 7th Annual Canadian Forum on Global Economic Sanctions returns to Toronto in-person and via livestream on September 22-23! Join a Canadian and international faculty of government of officials,...more

Harris Beach Murtha PLLC

Recent Enforcement Actions Indicate Heightened Scrutiny of BSA/AML Compliance and Digital Assets

Recent enforcement actions against banks indicate a new regulator emphasis on digital assets and Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance. Last year, Anchorage Digital Bank (Anchorage)—formerly Anchorage...more

Herbert Smith Freehills Kramer

FinCEN Warns of Russian Sanctions Evasion Attempts and Provides Guidance for Increased Vigilance

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) of the Treasury Department published guidance on increased vigilance for potential Russian sanctions evasion attempts. The FinCEN Alert follows the...more

K2 Integrity

Mobile Sports Gambling and Sports Betting Risks

K2 Integrity on

Gambling is an industry that, like it or not, is inherently associated with risk. In fact, its very existence is based on participants willing to take chances with (usually) their own hard-earned money. These truths, as well...more

King & Spalding

FinCEN Requests Comments on Beneficial Ownership Reporting Requirement; FinCEN’s Request For Information Moves U.S. Towards...

King & Spalding on

The United States Department of the Treasury (“Treasury”) is taking further action to combat corruption, money laundering, terrorist financing, tax fraud, and other illicit activities. Following its Advance Notice of...more

American Conference Institute (ACI)

[Virtual Conference] Navigating Russia Sanctions Complexities - September 27th, 10:00 am - 5:00 pm EDT

Unravel the multiple layers of primary and secondary Russia Sanctions and strengthen your analytical decision-making process. The Russia sanctions landscape continues to evolve in many significant ways. ACI’s 4th...more

Oberheiden P.C.

5 Anti-Money Laundering Compliance and Defense Tips

Oberheiden P.C. on

1. AML Laws - Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

Ballard Spahr LLP

Regulatory Round Up: FinCEN Solicits Comments on Due Diligence for Correspondent and Private Bank Accounts

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Final Post in a Three-Post Series Regarding Recent Regulatory Action by FinCEN - On September 29, 2020, the Financial Crimes Enforcement Network (“FinCEN”) published a request for comment on existing regulations regarding...more

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