Strengthening Compliance: Lessons From the OCC's Consent Order With Patriot Bank — Payments Pros – The Payments Law Podcast
Recent Developments in Anti-Money Laundering - The Consumer Finance Podcast
Investment Management Update – Exit Strategies
The UK Financial Intelligence Unit (UKFIU) has published its annual report on suspicious activity reports (SARs) for the period between April 2023 and March 2024. The annual report structure has been updated due to a number...more
In a series of settlements announced this year, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) penalized several broker-dealers for allegedly failing to file...more
Federal law enforcement takes money laundering and other suspicious transactions extremely seriously. Unfortunately, this does not mean that legal scrutiny is confined to the criminal actors and organizations that launder...more
Federal and State Financial Regulators Publish New Guidance on LIBOR Transition - The federal banking agencies, the NCUA and the CFPB, in conjunction with the state bank and state credit union regulators, have issued joint...more
In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more
Smaller banks and money services businesses should expand their AML compliance to mitigate human trafficking corporate liability. Aside from the Bank Secrecy Act, federal law creates corporate liability for financial...more
Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations. With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more
Prosecutors and regulators are targeting global banks. The beginning of 2018 has seen dominated by enforcement actions of financial institutions – the Federal Reserve’s unprecedented enforcement action against Wells Fargo;...more
Wednesday, the SEC Office of Compliance Inspections and Examinations (OCIE) announced its 2018 examination priorities, released in order to “improve compliance, prevent fraud, monitor risk, and inform policy.” ...more
It is rare these days for Republicans and Democrats to agree on political priorities – another profound grasp of the obvious. Recently, on Capitol Hill there appears to be some common ground on the issue of reforming AML...more
Financial institutions face enormous pressures with respect to anti-money laundering compliance. These burdens are about to grow with implementation of customer due diligence rules. In 2017, federal and state regulators...more
Post at a glance: • FinCEN imposes $8 million penalty against California’s biggest and oldest card club • Club failed to implement and maintain an effective anti-money laundering (AML) program and failed to detect,...more
FinCEN recentlty announced entry of a $2 million assessment against Lone Star National Bank, a private bank operating out of Texas, for the bank’s allegedly willful violations of the Bank Secrecy Act (“BSA”) and inadequate...more
In its Summer 2017 issue of Supervisory Insights, published last week, the Federal Deposit Insurance Corporation (“FDIC”) provides some insight into its examination process and outcomes for Bank Secrecy Act (“BSA”)/Anti-Money...more
The Western Union Company (“Western Union”) entered into a deferred prosecution agreement (“DPA”) on January 19th with the Department of Justice, based on alleged willful failures to maintain an effective AML program and the...more
The 2016 election will be remembered not only for the memorable presidential race but also for what was effectively a national referendum on cannabis. Eight states passed laws allowing its use. Medical marijuana is now...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
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 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