News & Analysis as of

Patriot Act Risk Management

Bradley Arant Boult Cummings LLP

A New Rule Embraces Modernity in the Customer Identification Process

Financial institutions across the United States have grappled with compliance requirements under the Customer Identification Program (CIP) Rule for more than two decades. A new exemption, approved in June 2025, promises...more

Fenwick & West LLP

Bank-Fintech Partnerships Under Scrutiny: What Fintechs Need to Know About AML Expectations

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Bank-fintech partnerships have transformed the financial services landscape, creating new opportunities and challenges for traditional banking institutions and innovative technology companies alike. In a typical arrangement,...more

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

K2 Integrity on

Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

K2 Integrity

How Efforts to Counter Terrorist Financing Have Evolved Since 9/11

K2 Integrity on

Since 9/11, countering the financing of terrorism (CFT) has been a focus of U.S. and international security policy, and an evolving feature of the regulatory and risk environment for authorities and the private sector. In the...more

Venable LLP

Keeping up with Anti-Money Laundering Rules

Venable LLP on

In 1970, Congress passed the Currency and Foreign Transactions Reporting Act, commonly known as the “Bank Secrecy Act” (BSA). The BSA is often referred to as an “anti-money laundering” (AML) law or jointly as “BSA/AML.” The...more

Orrick, Herrington & Sutcliffe LLP

New Syria, North Korea and Other Sanctions Provisions Enacted as Parts of the National Defense Authorization Act for Fiscal Year...

On December 20, 2019, President Trump signed into law the National Defense Authorization Act for Fiscal Year 2020 (“NDAA 2020”), which includes numerous sanctions-related provisions. The law includes the previously introduced...more

Ballard Spahr LLP

FinCEN Identifies Iran as a Jurisdiction of Primary Money Laundering Concern

Ballard Spahr LLP on

On October 25, 2019, FinCEN issued a final rule imposing the Fifth Special Measure against the Islamic Republic of Iran as a “jurisdiction of primary money laundering concern” (“Final Rule”) under Section 311 of the USA...more

K2 Integrity

Is Your AML Program Up to the Task?

K2 Integrity on

Fulfilling today’s requirements for anti-money laundering and counterterrorism financing/sanctions compliance is no easy task for financial institutions. ...more

Ballard Spahr LLP

The New Paradigm: Proposed Reforms of the AML/CFT Regime by The Clearing House

Ballard Spahr LLP on

Today we are very pleased to welcome guest blogger Greg Baer, who will address a series of significant issues posed by a detailed paper published by The Clearing House, a banking association and payments company that is owned...more

Foodman CPAs & Advisors

De-Risking 101

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Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

Proskauer - Corporate Defense and Disputes

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

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