News & Analysis as of

Know Your Customers Compliance

Baker Botts L.L.P.

Beyond the Fine: What Financial Gatekeepers Must Learn from Interactive Brokers’ OFAC Settlement

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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

Wiley Rein LLP

FCC Proposes First of its Kind $4.5 Million Penalty on Voice Provider for Alleged Know-Your-Customer Failures

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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

Ankura

Content Creators and the Risks for Money Laundering

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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

K2 Integrity

Fiat Ramps Unlocked: Practical Tips For Banks And Crypto Firms

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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

Bradley Arant Boult Cummings LLP

Community Banks and BSA/AML Compliance: The OCC’s Consent Order with Clear Fork Bank Proves Regulators Aren’t Only Focused on...

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

Holland & Hart LLP

The Corporate Transparency Act Compliance Deadline Looms—Lenders, Are Your Customers Ready? Are YOU Ready?

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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

Venable LLP

DOJ Revises Its Evaluation of Corporate Compliance Policy to Consider How Companies Address Risks Posed by AI

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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

Walkers

Global Legal Insights FinTech 2024: Bermuda chapter

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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

Mintz - Technology, Communications & Media...

Telephone and Texting Compliance News: Regulatory Update — FCC Resolves Investigation of Lingo Telecom, Finalizes Proposed...

In May, we reported that the Federal Communications Commission (Commission) had adopted a Notice of Apparent Liability (NAL) against a voice service provider, Lingo Telecom, LLC (Lingo), for transmitting illegally spoofed,...more

Guidepost Solutions LLC

Crypto Crackdown: 8 Key BSA/AML Fundamentals for FinTechs

In June 2024, multiple state regulators took joint action against Plutus Financial, Inc (Abra) ordering Abra to cease and desist certain operations in the U.S. and reimburse customers of virtual assets valued at $81.1 million...more

Ankura

The Importance of KYC/CDD Review in Preparing for a BSA/AML Program Examination

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The Bank Secrecy Act (BSA) and Anti-Money Laundering (AML) regulations are fundamental components of the financial industry’s efforts to combat financial crimes. As a BSA/AML Officer, it is crucial to ensure that your...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Fenwick & West LLP

Latest Updates in Trade Controls for the Tech Sector

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Melissa Duffy and Trevor Coval contributed their thought leadership to the American Conference Institute’s 14th Annual Global Encryption, Cloud & Cyber Export Controls Conference, held in San Francisco on May 14-16. Melissa...more

BakerHostetler

Key Export Control Developments During the First Quarter of 2024

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The first quarter of 2024 saw numerous developments on the export control front. This report summarizes the key developments and provides links to the relevant Federal Register notices and/or agency announcements....more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Venable LLP

Executive Order to Prevent Access to Americans' Bulk Sensitive Personal Data and Government-Related Data by Countries of Concern

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On February 28, 2024, the Biden Administration issued Executive Order (EO) 13873, focused on restricting certain transactions involving Americans' personal data, as well as sensitive government data, to specific countries....more

Venable LLP

Nonprofits Operating Abroad: Five Key Compliance Strategies

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With the current state of the world and heightened scrutiny of the nonprofit sector, it is critical that nongovernmental organizations (NGOs) with international reach routinely assess the effectiveness of their trade...more

J.S. Held

INDEPTH FEATURE: Anti-Money Laundering 2024

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Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more

Womble Bond Dickinson

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

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In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

The Volkov Law Group

OFAC Reaches Settlement with Cryptocurrency Company CoinList for Violations of Ukraine/Russia Sanctions

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On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more

Roetzel & Andress

New Federal Law to Create Reporting Requirements for Most U.S. Entities

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Many entities across the United States are about to have increased reporting requirements starting January 1, 2024. After a long anticipated-wait, FinCEN, the Financial Crimes Enforcement Network, issued a final rule on the...more

ArentFox Schiff

Investigations Newsletter: Binance to Pay Historic $4 Billion Fine

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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

Womble Bond Dickinson

Sportswashing: The New Money Laundering and Sanctions Avoidance Mechanism

Womble Bond Dickinson on

In the world of international finance and crime, criminals and terrorists have always sought innovative ways to launder money and avoid sanctions. One relatively recent method that has gained prominence is known as...more

J.S. Held

Three Ways to Use Analytic Rigor in Your AML Compliance Operations

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Introduction: Influx of Information Triggers Threats to Anti-Money Laundering Compliance - Information abounds. The internet, social media, and web 3.0 are full of content and it’s available with a few finger taps....more

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