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
Our Financial Services and White Collar, Government & Internal Investigations Groups unpack the Financial Crimes Enforcement Network’s new geographic targeting order aimed at combatting money laundering and other illegal...more
On March 11, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) requiring all money services businesses (MSBs) operating within 30 specified ZIP codes near the U.S.-Mexico border...more
The UK's capital markets are a vital economic driver, and also a significant source of money laundering risk. This is a difficult area of risk for regulators and law enforcement to understand and tackle, but progress is being...more
On October 10, 2024, the financial services community was stunned by the $3.1 billion settlement between the federal government and TD Bank over Bank Secrecy Act (BSA) and anti-money laundering (AML) violations. TD Bank’s...more
Mike Volkov often told the story of watching the Watergate Hearings as a teenager and being a seminal influence on his later professional life in the legal profession and government service. It was my first exposure to...more
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that will define most SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) as...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more
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
What You Need to Know - In October 2023, the Department of Treasury’s Office of Foreign Asset Control (OFAC) enacted multiple sanctions targeting the supply chain of fentanyl and other illicit drugs. In addition to...more
The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals. ...more
It would be the height of folly to claim that a single theme dominates the AML Act of 2020 (Act). The new law, enacted on January 1 of this year, is an extraordinarily wide-ranging and long overdue reform of the Bank Secrecy...more
Report on Supply Chain Compliance 3, no. 19 (October 1, 2020) - Leaked documents from the Financial Crimes Enforcement Network, including a trove of suspicious activity reports, show how nation-states and entities use...more
Compliance professionals face extraordinary risks – not just for the enterprise but personal risks. CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more
The UK Law Commission has published a report criticising existing anti-money laundering legislation and providing recommendations to improve the quality of Suspicious Activity Reports (SARs). What should we make of these...more
On May 9, 2019, the Financial Crimes Enforcement Network (FinCEN) issued interpretive guidance1 summarizing the application of the Bank Secrecy Act (BSA) rules to business models “involving money transmission denominated in...more
UBS Group agreed to pay a combined $15 million penalty to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”)and the SEC for regulatory deficiencies in its anti-money laundering compliance program. ...more
As early as 2007 the Russian Central Bank warned Danske about suspicious activity. In the same year the Estonian banking regulator warned the bank about suspicious transactions. In 2009 an internal whistleblower alerted the...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
Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more
The Department of Justice announced criminal FCPA charges against two individuals in connection with bribery payments to foreign officials in Chad and Uganda. The Justice Department’s announcement occurred on the heels of...more
The law and practice relating to financial crime and investigations is evolving fast. In the past 18 months we have seen two new Acts aimed at combatting financial crime (including the creation of two new corporate criminal...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