The UK Financial Conduct Authority (FCA) has issued finalised guidance on the treatment of politically exposed persons (PEPs) for anti-money laundering purposes. There is no significant shift in the FCA’s expectations of...more
July saw a number of updates regarding the prevention of money laundering in the UK, reflecting the Government’s stated commitment to ensuring that compliance requirements are effective yet not unnecessarily onerous for the...more
On December 1, 2021, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the “Manual”), which provides guidance to...more
Introduction - The art market is characterised by high-value, portable items that can be bought and exchanged quickly and often confidentially. These features, which make the market inherently vulnerable to many types of...more
The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more
The Financial Crimes Enforcement Network (FinCEN) and federal banking regulators recently issued a Joint Statement intended to clarify the due diligence obligations of banks under the Bank Secrecy Act (BSA) regarding...more
In response to inquiries from the financial industry as to how to assess risks of potential illegal activity with respect to beneficial owners who are “politically exposed persons” (PEPs) overseas, federal bank regulators...more
Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more