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Recent Developments in Anti-Money Laundering - The Consumer Finance Podcast
Investment Management Update – Exit Strategies
On August 4, 2025, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice FIN-2025-NTC1 (the “Notice”) to address mounting concerns over regulatory risks related to convertible virtual currency (“CVC”) kiosks, also...more
Key Takeaways - - The Financial Crimes Enforcement Network’s recently issued notice, which addresses regulations and increased rates of fraud surrounding convertible virtual currency kiosks, carries significant implications...more
The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more
El 20/10/23, FinCEN emitió Señales de Alerta (“Red Flags”) sobre el Financiamiento del Terrorismo para ayudar a las instituciones financieras a identificar flujos de financiamiento para la organización terrorista Hamás en...more
Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more
On September 8, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released an alert regarding a notorious virtual currency scam called “pig butchering,” because, unfortunately, it resembles the “fattening a hog before...more
On October 11, 2022, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN) announced settlements for approximately $24 million and $29 million,...more
The Office of Foreign Assets Control (“OFAC”) and the Financial Crimes Enforcement Network (“FinCEN”) announced on October 11 simultaneous settlements with Bittrex, Inc. (“Bittrex”), a virtual currency exchange and hosted...more
Greetings, and thank you for taking a look at our new monthly crypto enforcement newsletter. Our goal is to share five topics each month that we believe are of significance in the world of crypto enforcement—particularly as...more
FinCEN and Bank Secrecy Act Reporting - On March 7, 2022, the Financial Crime Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury alerted financial institutions “to be vigilant against efforts to...more
With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more
The U.S. Government Accountability Office (“GAO”) recently issued a public version of a more detailed and confidential report previously sent to Congress summarizing the GAO’s review of the use of virtual currencies to...more
The US Department of the Treasury (Treasury) has released the results of its review of economic and financial sanctions first announced in December 2020 by then President-elect Biden (Report). From that review, Treasury has...more
Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more
On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). ...more
On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more
Government Alleges Systemic and Deliberate AML Failures - Filings Describe Tools for CVC Exchanges to Use for Customer Due Diligence and Transaction Monitoring - The Financial Crimes Enforcement Network (“FinCEN”) and...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
The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...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
Federal Regulation Actions Frozen Pending Review from New Administration - On January 20, 2021, newly inaugurated President Joe Biden issued a memorandum to the Heads of Executive Departments and Agencies asking current...more
In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more
Proposed Change Would Expand BSA Definition of “Money” to Include Virtual Currency - The Financial Crimes Enforcement Network (“FinCEN”) and the Federal Reserve Board (“Board”) have requested comment on an important...more
The prevalence, sophistication, and severity of ransomware attacks have increased anti-money laundering risks faced by financial institutions both as targets of ransomware attacks and as potential intermediaries in...more
Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town. The Commodity Futures Trading Commission recently finished its fiscal year with...more