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]
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
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
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
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
The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more
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
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
ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....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
Although the Corporate Transparency Act (CTA”) was adopted in 2021, implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) established regulations. The deadline,...more
U.S. Senators Elizabeth Warren and Roger Marshall are introducing the Digital Asset Anti-Money Laundering Act (the "Act"), with the aim of bringing the crypto and digital asset ecosystem under existing anti-money laundering...more
Two recent guilty pleas involving a cryptocurrency exchange serve as a reminder to all money services businesses (“MSBs”)—including those ostensibly located outside the United States but that conduct business there—of the...more
From manufacturers to financial and other professional service providers, no prudent company welcomes attention based upon an unfortunate client or customer affiliation. Still, in our media-saturated world, “foreign” and...more
Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more
On October 19, 2021, FinCEN, the U.S. Government’s lead AML regulator, exercised its regulatory relief authority to allow casinos and card clubs to employ “non-documentary means” to verify patrons’ identity. The original...more
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more
On August 10, 2021, the Commodity Futures Trading Commission (CFTC) and the Financial Crimes Enforcement Network (FinCEN) announced a near-record settlement of $100 million with BitMEX, a cryptocurrency derivatives exchange....more
As cryptocurrency’s market cap surpasses the $2.5 trillion mark and continues to climb, global regulators have turned their attention to understanding and addressing the risks surrounding digital assets. In recent years,...more
Auto dealerships and lenders are likely familiar with “know your customer” requirements, which typically involve obtaining identification information from customers and verifying that information. Most lenders are also...more
The Anti-Money Laundering Act of 2020 (the “AMLA”), which became law January 2, 2021 with Congress’ override of then President Trump’s veto of the Defense Appropriations Act of 2021 included provisions bringing dealers in...more
Executive Summary - The U.S. Congress recently passed the Corporate Transparency Act (“CTA”) as part of the 2021 National Defense Authorization Act. The CTA requires certain corporations, limited liability companies and...more
The Corporate Transparency Act (CTA), part of the 2021 National Defense Authorization Act enacted into law on January 1, 2021, will impose new beneficial ownership reporting requirements on many companies. The stated purposes...more
Effective as of January 1, 2021, Congress enacted - over President Trump's veto - the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (the "NDAA"). As with any U.S. defense bill, the NDAA...more