A Good Lickin'
All Things Investigation: Due Diligence and Drama: A Deep Dive into Art World with Daniel Weiner
FCPA Compliance Report: Navigating the Complexities of FTO Designations and Compliance in Mexico and Latin America
The Presumption of Innocence Podcast: Episode 50 - Hidden in Plain Sight: How Kleptocrats Exploit U.S. Financial Systems
Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations
Regulatory Ramblings: Episode 56 - The Intersection of Financial Crime and Cryptocurrencies with Chengyi Ong
Digital Planning Podcast Episode: Estate Planning and the Corporate Transparency Act
Season 2 - Episode 2 - A Whistleblowers Nightmare: The Uncovering of the 1Malaysia Development Berhad Scandal
Guidepost in Motion EP24: State of Compliance with Alixandra Smith Part 1
RICO Conduct (18 U.S.C. §§ 1962(a-d)) - RICO Report Podcast
The Justice Insiders: Largest Bitcoin Seizure in DOJ History – Crypto Can Be Traced!
Integrity Matters: AML Trends for 2022
Anatomy of a Successful Motion to Dismiss in RICO Case
Anti-Money Laundering Act Priorities Released: Takeaways for Companies
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
Argentina: A Look at the Case of Lázaro Báez - Laundering the Proceeds of Corruption and Tax Fraud
Cryptocurrency: Wild West or Wall Street? [More with McGlinchey, Ep. 22]
Episode 117 -- FCPA Update: Samsung FCPA Settlement; Braskem Former CEO Indicted; Transport CEO Convicted after Trial
Episode 116 -- Alstom Executive Convicted of FCPA and Money Laundering Offenses
Assessing Your Money Laundering Risk with Jennifer McEntire
The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more
In the possible final stage of the Alpine Securities saga, Judge Clark Waddopous of the United States District Court for the District of Utah issued an opinion granting the Securities and Exchange Commission’s (“SEC”) motion...more
On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more
The Blockchain Bi-Weekly presented by the Polsinelli Blockchain+ team is a rundown of some of the key stories in the Web3, blockchain and crypto ecosystems curated by our attorneys navigating the intersections of code, smart...more
On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more
The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more
Priorities Echo Prior Alerts and Enforcement Actions - The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year 2024. This release...more
The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more
On July 31, 2023, the United States Securities and Exchange Commission (“SEC”) published an alert outlining deficiencies the Department of Examinations has observed in broker-dealers’ (“BD”) compliance with anti-money...more
The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements. There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will...more
In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more
First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more
The Morgan Lewis Year in Review highlights key US Securities and Exchange Commission (the SEC or the Commission) and Financial Industry Regulatory Authority (FINRA) enforcement and examination developments, and cases...more
The Financial Industry Regulatory Authority is not known for its aggressive enforcement record. But that may be changing. FINRA recently fined BNP Paribas for $15 million for anti-money laundering deficiencies in the...more
For the first time, a broker-dealer, Central States Capital Markets, LLC (Central States), has been prosecuted for violating the Bank Secrecy Act (BSA). ...more
On May 16, 2018, the Securities Exchange Commission (“SEC”) announced it had settled charges against a registered broker-dealer, its clearing firm, and its chief compliance and anti-money laundering (“AML”) officer brought...more
Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more
On June 5, the SEC filed suit against Salt Lake City-based Alpine Securities, Corp. (“Alpine”). The complaint, filed in the Southern District of New York, alleges that the broker-dealer ran afoul of AML rules by “routinely...more
This post discusses individual liability in AML/BSA enforcement, which is an area of increasing attention. Indeed, according to public statements by the government, individual liability is the focus of enhanced scrutiny...more
On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more
On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed rulemaking that would require registered investment advisers, including certain hedge funds and asset managers, to establish anti-money laundering...more
The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more
On Tuesday, the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would require SEC-registered investment advisers, including private equity and hedge funds, to comply...more