Last Friday, the U.S. Department of Justice (DOJ) unsealed its first indictment against a foreign national for providing material support to a Mexican drug cartel that the current administration recently designated a foreign...more
Amendments to the Cayman Islands Proceeds of Crime Act came into effect on 2 January 2025 and include revisions to the suspicious activity report (SAR) process to the Financial Reporting Authority (FRA). In addition to a...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
Quicker and easier sharing of customer information relating to economic crime concerns between firms in the UK financial sector is being encouraged by provisions in the Economic Crime and Corporate Transparency Bill which is...more
On January 13, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions on how to detect and report suspicious financial activity that may be related to human smuggling along the...more
This alert addresses the explosion in popularity of daily fantasy sports (“DFS”) sites and the money-laundering potential that DFS sites may offer to criminals around the world. It then explains potential legal liability...more
Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more
The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...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 September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more
FinCEN is an active law enforcement agency. They have taken on more responsibility over the last five years for AML enforcement, and they show no signs of letting up. FinCEN’s proposal to expand beneficial ownership...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
Anti-money laundering compliance is a very difficult task. The number of risks is exponential. AML compliance officers have an innovative and rich history of compliance techniques and strategies. In the end, AML compliance...more
Domestic Developments - Florida. Anthony Murgio and Yuri Lebedev, operators of bitcoin exchange service Coin.mx were arrested on July 21, 2015 for operating the exchange without a money transmission license. The U.S....more
FinCEN has many important responsibilities but one of its more interesting assignments is oversight of anti-money laundering compliance by casinos (and card clubs). Casinos are under increasing scrutiny these days for lax AML...more
On March 10, 2015, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) named Banca Privada d’Andorra (BPA) a foreign financial institution of “primary money laundering concern,” a measure that will...more
Compliance programs depend on accurate and timely information. AML compliance centers on sifting through thousands of transactions and matching them against risk profiles. ...more