All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
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
In July 2025, the U.S. Congress advanced a landmark package of legislative measures aimed at establishing a comprehensive federal framework for the regulation of cryptocurrencies and stablecoins. ...more
On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of its 2024 investment advisor AML rule for registered investment...more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has significantly increased its focus on sanctions compliance for “financial gatekeepers,” including financial institutions and other firms...more
On August 28, 2024, Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) that imposes comprehensive anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements on...more
In a development that underscores the Federal Trade Commission’s (FTC) growing scrutiny of the “merchant of record” model, the commission announced a $5 million settlement with UK-based Paddle.com Market Limited (Paddle),...more
On May 1, 2025, the Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) regarding the Huione Group, a foreign financial institution located in Cambodia. This proposal, enacted under...more
On April 22, the Fourth Circuit declined to reconsider a panel ruling that found a credit union could not be held liable for a scam in which fraudsters diverted over $560,000 from a metal fabricator through unauthorized ACH...more
As global trade policy evolves faster than ever, now is the time to connect with your peers, discover new strategies, and most importantly, hear from the regulatory agencies on the front lines of policy change. ACI’s 15th...more
The crypto industry is evolving rapidly, and regulatory enforcement is keeping pace. Businesses engaged in crypto transactions, custody, lending, trading, or payments must navigate know your customer (KYC) and anti-money...more
On 26 February 2025, the Financial Conduct Authority (FCA) published a portfolio letter (Letter) explaining its supervision priorities for the asset management and alternatives portfolios....more
On February 4, 2025, the Federal Communications Commission (FCC or Commission) released a Notice of Apparent Liability for Forfeiture (NAL) against voice service provider Telnyx LLC (Telnyx) for alleged violations of the...more
YouTube is a force of nature. If one requires information on how to build a cabin from mud and twigs, there is a video for that. If you want to watch someone clean up crime scenes, there is a whole YouTube channel for that...more
On his first day in office, President Donald Trump signed an executive order that initiates the process of designating certain drug cartels as foreign terrorist organizations. The executive order is primarily focused on...more
Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more
Ask any chief information security officer (CISO), cyber underwriter or risk manager, or cybersecurity attorney about what controls are critical for protecting an organization’s information systems, you’ll likely find...more
Imagine sitting in your living room, enjoying a cup of your favorite morning coffee, and you open your mail to discover that you recently opened a new bank account at XYZ Bank, unbeknownst to you. Or maybe you receive an...more
On December 4, 2024, the CFTC's Division of Enforcement ("Division") released its enforcement results for Fiscal Year 2024. The results reflected an all-time high for monetary relief, mainly from its resolution of off-channel...more
On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s...more
The January 1, 2025, deadline imposed by the Corporate Transparency Act (CTA) for all “reporting companies” formed prior to 2024 to file their initial beneficial ownership reports with FinCEN is rapidly approaching. Given the...more
The Department of Justice's Criminal Division is "using more tools than ever before to identify corporate misconduct and to encourage companies to be good corporate citizens," according to Nicole Argentieri, Principal Deputy...more
In a notice published on September 9, 2024, announcing a proposed rule and request for comment (“Proposed Rule”), the U.S. Department of Commerce called for new reporting requirements for the development of certain advanced...more
A shrinking legislative calendar and the fallout from November’s election results – no matter which party gains the upper hand in the battle for control of Congress – are likely to doom lawmakers’ efforts to pass...more
On August 19, the U.S. Treasury Department officially withdrew a contentious proposal from 2020 that aimed to impose know-your-customer requirements on non-custodial cryptocurrency wallets....more
Since the announcement of its Fintech strategy in November 2017, the Bermuda government has positioned Bermuda as a market-leading jurisdiction with respect to Fintech, with a view to Bermuda operating as an innovation hub...more