Popular, Compliance, Financial Crimes

US Corporate Governance — 2025 Midyear Review

Herbert Smith Freehills Kramer on 7/8/2025

The Financial Crimes Enforcement Network (FinCEN) issued an interim final rule in March 2025 that removes requirements for US companies to report beneficial ownership information under the Corporate Transparency Act (CTA)....more

10 Important Facts About FinCEN’s Whistleblower Program

Oberheiden P.C. on 5/13/2025

The Financial Crimes Enforcement Network (FinCEN) is one of a handful of federal authorities that have adopted whistleblower programs focused on facilitating enforcement in hard-to-target areas. While FinCEN focuses its...more

Breaking News: Corporate Transparency Act - Filing Deadlines Can Be Ignored for Now and Maybe Forever for Some

Shipman & Goodwin LLP on 3/5/2025

The Financial Crimes Enforcement Network of the U.S. Department of the Treasury (FinCEN) has changed the rules once again on the Corporate Transparency Act (CTA). Despite recently announcing that the new filing deadline for...more

Corporate Transparency Act Update: FinCEN Extends Reporting Deadline for Companies

Weintraub Tobin on 2/26/2025

On February 18, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice extending the deadline for reporting companies to file their Beneficial Ownership Information (BOI) reports under the Corporate...more

How Corporations Can Protect Themselves by Conducting Supply Chain Due Diligence

Guidepost Solutions LLC on 1/21/2025

In today’s complex global market, companies face significant risks when it comes to managing their supply chains. The recent criminal complaints against major tech firms like Apple, Dell, and Microsoft for allegedly using...more

AML/CTF Asset Due Diligence Obligations: CSSF Provides Clarifications in an initial Q&A

Goodwin on 1/17/2025

On 13 December 2024, the Commission de Surveillance du Secteur Financier (CSSF) published the first FAQ to assist professionals in the investment sector supervised, authorised, or registered by the CSSF in complying with...more

What’s Ahead as Corporate Transparency Act Comes to a Crossroads

Farella Braun + Martel LLP on 1/15/2025

The recent whiplash regarding the validity of the Corporate Transparency Act (CTA)—it was enjoined just to particular parties, then enjoined nationwide, then un-enjoined, then enjoined again, while other courts let it...more

Top 10 International Anti-Corruption Developments for December 2024

Morrison & Foerster LLP on 1/14/2025

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

First Ever Targeted Guidance On Financial Institutions’ Compliance With Export Administration Regulations

K2 Integrity on 10/22/2024

On 9 October 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) published its first ever unilateral guidance specifically addressed to financial institutions (FIs). The Guidance to Financial...more

TD Bank: Part 2 – When Profits Trump Compliance: A Recipe for Corporate Disaster

Thomas Fox - Compliance Evangelist on 10/15/2024

We continue our exploration of the resolution of the AML/BSA enforcement action involving TD Bank US (the Bank), which is wholly owned by TD Bank Group, a publicly traded (NYSE: TD) international banking and financial...more

TD Bank: Part 1-Money Laundering and the China Syndrome

Thomas Fox - Compliance Evangelist on 10/14/2024

Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

Corruption and modern slavery

Society of Corporate Compliance and Ethics... on 9/4/2024

In my July column, I wrote about the connection between corruption and the environment. But corruption also has a link to the “S” of the environmental, social, and governance (ESG) pillars. Corruption is both a cause and a...more

The Corporate Transparency Act: Key Deadline Fast Approaching and Other Recent Updates for Companies

Parker Poe Adams & Bernstein LLP on 8/30/2024

If your business has not yet focused on the Corporate Transparency Act (CTA), it is time to do so. Every entity formed or registered in the U.S. before January 1, 2024, must file beneficial ownership information (BOI) reports...more

What Is an “Effective AML/CFT Compliance Program”?

Perkins Coie on 8/23/2024

The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

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

Guidepost Solutions LLC on 5/24/2024

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

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

Dorsey & Whitney LLP on 3/18/2024

Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

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

Womble Bond Dickinson on 2/7/2024

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

Top challenges for white collar crime and investigations lawyers in 2024

A&O Shearman on 1/26/2024

We asked our global white collar crime team for their views on the key challenges in 2024 for in‑house investigations teams and white collar crime lawyers, and how to manage the associated risks. Here is what they said. ...more

The Corporate Transparency Act and FinCEN Final Rule

Tucker Arensberg, P.C. on 8/7/2023

Important New Filings Will Be Required Beginning in 2024 - The United States does not currently have a centralized repository of data about who owns and operates legal entities within its borders. That soon will change....more

TD Bank Eats $225 Million Termination Fee After AML Failures Doom Merger

The Volkov Law Group on 5/25/2023

How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more

NFTs Used to Serve Complaint; Treasury Official, SEC Chairman Address Crypto Compliance; NYAG Sues Crypto Exchange; DOJ Takes Down...

BakerHostetler on 3/20/2023

NFT Integration Software Released; NFTs Used to Serve Complaint in Civil Action - According to a recent press release, a major U.S. software company has launched a suite of tools that will allow users to “enter the Web3 and...more

New York Fines Crypto Trading Platform $30M In First-Ever DFS Crypto Settlement

A&O Shearman on 8/17/2022

On August 2, 2022, New York State’s Department of Financial Services (“DFS”) announced that Robinhood Crypto, LLC (“RHC”), a trading platform that allows customers to transact in cryptocurrencies, had agreed to pay a $30...more

DOJ Cryptocurrency Guidance Outlines Enforcement Partnerships (Part II of II)

The Volkov Law Group on 11/3/2020

DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more

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