The evolving U.S.-Mexico geopolitical relationship is now fundamentally burdened by the growing regulatory, enforcement, and real risks tied to cartel activity, drug trafficking and the fentanyl trade, immigration, and a...more
Matt Bisanz interviews Ross Delston, a financial crime compliance expert and former FDIC attorney. They discuss his views on the trends we should expect to see in financial crimefighting and AML compliance over the next few...more
FinCEN seeks to safeguard the investment adviser sector from illicit finance as evidenced by the issuance of the Final Investment Adviser Rule on 8/28/24 with a compliance date of 1/1/26. The investment adviser sector final...more
El 15 de febrero de 2024, FinCEN publicó un Aviso de Reglamentación Propuesta (NPRM) que requeriría que ciertos asesores de inversiones (Investment Advisers) apliquen requisitos de ALD/FT conforme con la Ley de Secreto...more
On 2/15/24, FinCEN published a Notice of Proposed Rulemaking (NPRM) that would require certain investment advisers to apply AML/CFT requirements pursuant to the Bank Secrecy Act, including implementing risk-based AML/CFT...more
February 29, 2024- The Federal Reserve Bank of New York has released a case study focused on pension fund investments in affordable apartments. February 29, 2024- The Financial Action Task Force (FATF) issued an...more
January 1, 2024 is quickly approaching and it will be a milestone for small businesses and their owners. Why? Because it is the effective date of the Corporate Transparency Act (the “Act”) – historic legislation that requires...more
On March 9, FinCEN informed U.S. financial institutions that last month the Financial Action Task Force (FATF) suspended the Russian Federation’s membership after determining that the country’s “actions unacceptably run...more
October 31, 2022- Securities and Exchange Commission Commissioner Caroline A. Crenshaw gave remarks at the inaugural ECGI Responsible Capitalism Summit entitled, "Moving Forward in Our Lane."...more
There is no doubt 2022 has signalled a renewed focus on beneficial ownership transparency. White & Case partners Jonah Anderson and Anneka Randhawa, and associate Laura Higgins have collaborated with Hannah Lilley and Michael...more
The Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (Notice) on Dec. 9, 2021, requesting public comment on ways to enhance the transparency of the domestic real estate market...more
Key considerations for banks engaging with governments and peer institutions to improve financial crime compliance systems - Every year, banks spend billions of dollars on core financial crime compliance systems and are...more
Fourth and Final Post in a Series on the FATF Plenary Outcomes - As we have previously blogged, the Financial Action Task Force (“FATF”) held its fourth Plenary on June 21-25, inviting delegates from around the world to...more
The U.S. Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the U.S. Federal Reserve System (FRB) proposed new rules that would expand the applicability of recordkeeping and travel rule requirements,...more
Indictment Again Highlights the Role of Correspondent Banking in Money Laundering - On May 28, 2020, the U.S. Department of Justice (“DOJ”) unsealed a 50-page indictment against 28 North Korean and 5 Chinese bankers...more
Earlier this month, senior officials of the global money laundering and terrorist financing watchdog—the Financial Action Task Force (FATF)—issued a paper identifying challenges, good practices, and policy responses to new...more
On May 18, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advisory “to alert financial institutions to rising medical scams related to the COVID-19 pandemic. This [A]dvisory contains red flags, descriptions of...more
On May 4, the Financial Action Task Force (“FATF”) issued a paper entitled “Covid-19-Related Money Laundering and Terrorist Financing – Risk and Policy Responses (“Paper”). ...more
Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more