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
On June 25, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its first orders under the FEND Off Fentanyl Act, targeting three Mexican financial institutions: CIBanco S.A. (CIBanco),...more
Investing in the cannabis industry is not without its risks, given the evolving regulatory landscape and the varying state and federal statuses of the product itself. The Financial Crimes Enforcement Network (FinCEN) has...more
The evolving regulatory landscape for marijuana-related businesses poses unique compliance challenges for firms in the securities industry. The Financial Crimes Enforcement Network (“FinCEN”) continues to enforce its 2014...more
While financial institutions, on the one hand, are in the process of implementing and preparing to apply the fundamental amendments and changes that will take place in upcoming years by the EU AML Package—entering into force...more
On March 28, 2025, the Internal Revenue Service (“IRS”)’s criminal investigative arm, IRS Criminal Investigation (“IRS-CI”), announced that it would be implementing a new program called CI-FIRST (Feedback in Response to...more
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
Public-private partnerships across the world between financial institutions, financial intelligence units and investigative authorities have laid the foundation to advance criminal investigations. However, there is further...more
In 2024, FinCEN and the federal bank regulators announced more than three dozen enforcement actions against banks and individuals arising from alleged Bank Secrecy Act (BSA), anti-money laundering (AML), and countering the...more
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
The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more
The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of New York, denying a...more
On September 29, the Financial Crimes Enforcement Network (“FinCEN”) entered into a consent order with Shinhan Bank America (“SHBA”), which imposed a $15 million dollar civil penalty against SHBA for allegedly willfully...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
The Financial Crimes Enforcement Network (FinCEN) and the Commodity Futures Trading Commission (CFTC) reached one of the largest-ever resolutions with a cryptocurrency exchange on August 10, 2021. BitMEX is virtual currency...more
Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more
As the financial services industry prepares for expanded criminal and civil enforcement under the Bank Secrecy Act (“BSA”) with the passage of the Anti-Money Laundering Act of 2020, FinCEN’s recent case against Capital One...more
On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more
This month’s coordinated U.S. multi-agency enforcement action against online broker Interactive Brokers (IBKR) signals authorities’ ongoing concerns about anti-money laundering/combating the financing of terrorism (AML/CFT)...more
Government Suggests that Unusual Pleas are Just the Tip of an Iceberg - Chinese law generally prohibits its citizens from converting more than $50,000 in Chinese yuan into foreign currency in a year. On Monday, two men...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...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
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