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Enforcement Actions Anti-Money Laundering Money Services Business

Ballard Spahr LLP

FinCEN’s Southwest Border Geographic Targeting Order Faces Challenges in Texas and Southern California

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In March, we wrote about the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issuing a Geographic Targeting Order (GTO) aimed to combat Mexican-based drug cartels. The GTO signals Treasury’s efforts to...more

Morrison & Foerster LLP

FinCEN Joins the Government-Wide Pursuit of Cartels - UPDATED 3/18/25

On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) specifically aimed at combatting Mexico-based cartels and other criminals along the southwest border of the United...more

Harris Beach Murtha PLLC

[Webinar] Third Party Risk is Your Risk - January 24th, 11:00 am - 12:00 pm EST

• Highlights of recent joint agency guidance on Third-Party Risk Management (3PRM) • How 3PRM considerations have increased in importance in BSA/AML compliance programs and enforcement actions • Lessons learned from...more

Ballard Spahr LLP

Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Multiple Billions – While its Founder, Owner and...

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As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the “Company”), has entered into a plea agreement with the U.S. Department of Justice (“DOJ”)....more

McGlinchey Stafford

Scared Of Your Clients’ Involvement With Cryptocurrency?

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Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more

Polsinelli

Superman29 - Welcome to the Phantom Zone

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In a lesson to everyone that the use of foolish monikers will come back to haunt you, Kais Mohammad, 36, a.k.a. “Superman29,” has met his Kryptonite - the U.S. Department of Justice. ...more

American Conference Institute (ACI)

[Virtual Forum] Anti-Money Laundering and Financial Crime - July 14th - 15th, 8:00 am - 5:00 pm EDT

Virtually attend the forum to learn how to align your compliance program with the amended Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) regulations effective 2020/2021. In June 2019 amended...more

Foodman CPAs & Advisors

If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)

FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more

Jones Day

Financial Crimes Enforcement Network Consolidates Guidance on Virtual Currencies

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The Situation: The Financial Crimes Enforcement Network ("FinCEN") released interpretive guidance concerning the application of the Bank Secrecy Act ("BSA") and the anti-money laundering ("AML") regulations to certain...more

Wilson Sonsini Goodrich & Rosati

Virtual Currency Guidance + Enforcement Actions = AML Regulators Are Watching

A few days before thousands of blockchain industry participants poured into New York for “Blockchain Week,” the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on virtual currencies...more

Sheppard Mullin Richter & Hampton LLP

FinCEN – We Will Identify Where Compliance Is Not Taking Place And Take Appropriate Action

Last week we reported that FinCEN had issued new guidance addressing cryptocurrency and other convertible virtual currency. The need for compliance was reinforced this week. In a speech by Sigal Mandelker, Under Secretary for...more

Orrick - On the Chain

FinCEN Shows a Little Bite to Go with Its Bark

Orrick - On the Chain on

Last week, the Financial Crimes Enforcement Network (FinCEN) backed up its strong public statements about enforcing the anti-money laundering (AML) laws with respect to cryptocurrency by bringing an enforcement action against...more

Fox Rothschild LLP

FinCEN Announces First-Ever Enforcement Action Against Bitcoin Trader For Violations Of BSA

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Last week, the Financial Crimes Enforcement Network (FinCEN) announced its first-ever civil penalty against a cryptocurrency exchanger for willful violations of the Bank Secrecy Act (BSA). According to the FinCEN Assessment...more

Burr & Forman

FinCEN Announces Civil Monetary Penalty for Virtual Currency Exchanger

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On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) announced its first enforcement action against a peer-to-peer virtual currency exchanger....more

Ward and Smith, P.A.

Should You Bank a Virtual Currency Business?

Ward and Smith, P.A. on

Virtual currencies like Bitcoin and Ethereum have spawned many types of businesses that need banking services. Many banks "de-risk" -- do not provide banking services -- to these businesses. Many virtual currency...more

Pillsbury Winthrop Shaw Pittman LLP

Beyond BSA Compliance: Human Trafficking Corporate Liability for Small Banks and MSBs

Smaller banks and money services businesses should expand their AML compliance to mitigate human trafficking corporate liability. Aside from the Bank Secrecy Act, federal law creates corporate liability for financial...more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

Not an ideal report on the state of affairs for Zelle, the big banks’ payment-platform answer to Venmo. The Times reports that the “same features that make Zelle so useful for customers, its speed and ubiquity, have made it...more

Wilson Sonsini Goodrich & Rosati

Anti-Money Laundering Obligations for Virtual Currency Companies

Virtual currency businesses are under scrutiny by U.S. anti-money laundering (AML) regulators. Earlier this year, U.S Treasury Secretary Steven Mnuchin emphasized that virtual currencies are subject to AML regulations. He...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Action Demonstrates the Agency’s Ability to Use Anti-Money Laundering Laws Against Non-U.S. Entities

On Wednesday, July 27, 2017, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $110 million fine levied against BTC-e, a digital currency exchange, for BTC-e’s alleged refusal to abide by...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

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