Wait, that’s covered? Insurability of Fines and Penalties Flowing From a Cybersecurity Breach
FCPA Compliance and Ethics Report-Episode 31-the FCPA Year in Review, Corporate Enforcement Actions
FCPA Compliance and Ethics Report-Episode 30-Interview with the FCPA Professor-Part 2
Condo complaints not in writing?
Health Data on Leased Photocopier Costs Company $1.2m—What Others Can Learn
On February 27, 2025, in a move to comply with the Treasury’s commitment to reducing regulatory burdens on businesses, FinCEN announced that it will not impose fines or penalties or take other enforcement actions against any...more
Below is a statement from the Financial Crimes Enforcement Network (FinCEN) released February 27, 2025 stating it will not take any enforcement action against a Reporting Company that fails to file or update a beneficial...more
FinCEN announced that it will not issue any fines or penalties or take any other enforcement actions against any companies based on any failure to file or update beneficial ownership information (BOI) reports pursuant to the...more
Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more
Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more
Have you forgotten about the Beneficial Ownership Information (BOI) Report established by the Corporate Transparency Act (CTA) of 2021? Owners of qualifying domestic entities, as well as those qualifying foreign entities...more
Background - The Corporate Transparency Act of 2019 (“CTA”) became effective on January 1, 2024. Under the CTA, all “reporting companies” must file a Beneficial Ownership Information (BOI) report with the Financial Crimes...more
Are you thinking of moving to another country? Over the past decade, a record number of U.S. citizens have decided to live and work abroad. There are many issues you may not have considered that will impact any decision to...more
It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
When the Corporate Transparency Act took effect earlier this month, most commentary rightly focused on the obligations it imposed and the measures necessary to comply with its terms. As part of that analysis, commentators...more
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more
CTA Denial #6: “If I get caught, I’ll just pay the fine.” The CTA provides for civil fines of $500 per day, up to $10,000, per violation of the Act. The Act also provides for a criminal penalty of up to two years’...more
Binance to Pay Historic $4 Billion Fine - Binance Holdings Limited, the operator of the world’s largest cryptocurrency exchange, agreed to pay $4.3 billion to resolve allegations that it violated the Bank Secrecy Act (BSA)...more
With 2024 almost upon us, this means that for millions of companies across the United States, new compliance requirements under the Corporate Transparency Act (“CTA”) are about to take effect. In fact, the Financial Crimes...more
Background - In January 2021, the United States Congress passed the Corporate Transparency Act (CTA) as part of the Anti-Money Laundering Act of 2020. This law, while intended to prevent criminal actors from hiding and...more
New Crypto Products Launch in Custody, Cloud Collaborations and Stablecoins - This week, a major U.S. financial institution announced that its Digital Asset Custody platform is now live in the United States. According to...more
Note to Government Personnel: Don’t Disclose SARs - This week, major developments unfolded in the cases against two former federal government employees for their respective roles in disclosing Suspicious Activity Reports...more
ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd. a...more
ANTICORRUPTION DEVELOPMENTS - Mega International Commercial Bank Co. Ltd. Fined $29 Million - On January 17, 2018, the U.S. Federal Reserve Board assessed Taiwan based bank Mega International Commercial Bank Co. Ltd....more
Post at a glance: • FinCEN imposes $8 million penalty against California’s biggest and oldest card club • Club failed to implement and maintain an effective anti-money laundering (AML) program and failed to detect,...more
ANTICORRUPTION DEVELOPMENTS – Global Compliance Overhaul for SAP as DOJ and SEC Investigate Payments Allegedly Related to South African Government Contracts – On October 26, 2017, German software company SAP SE...more
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
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
The Financial Crimes Enforcement Network (FinCEN) announced the assessment of a $37.5 million civil money penalty against TD Bank, N.A. for failure to file suspicious activity reports related to the massive Ponzi scheme...more