News & Analysis as of

White Collar Crimes BSA/AML Money Laundering

DLA Piper

Recent Settlement Demonstrates DOJ’s Focus on Foreign Entities Misrepresenting Anti-Money Laundering Compliance

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The US Department of Justice (DOJ) has announced that Wall Street Exchange (WSE), a Dubai-based money exchange service provider, entered into a non-prosecution agreement (NPA) and agreed to pay more than $9.2 million to...more

The Volkov Law Group

Episode 343 -- TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations

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How does a respected financial institution turn into a criminal operation? In this episode of Corruption, Crime, and Compliance, host Michael Volkov dives into the record-breaking $3 billion settlement between TD Bank and the...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

The Volkov Law Group

TD Bank’s Rotten Corporate Culture — From its Store-Level Operations to its Board’s Audit Committee (Part IV of IV)

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TD Banks’ complete compliance disaster was reflected in every aspect of TD Bank’s business and compliance operations. It is not surprising that TD Bank’s deficient BSA and AML compliance program was known by its Board of...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 2 – When Profits Trump Compliance: A Recipe for Corporate Disaster

We continue our exploration of the resolution of the AML/BSA enforcement action involving TD Bank US (the Bank), which is wholly owned by TD Bank Group, a publicly traded (NYSE: TD) international banking and financial...more

Ballard Spahr LLP

Former Bank Compliance Chief Seeks Appellate Review of OCC Administrative Enforcement Proceeding Dismissal

Ballard Spahr LLP on

In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

The Volkov Law Group on

The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...more

The Volkov Law Group

Prosecutors Embrace Criminal AML Charges in Corruption Cases

The Volkov Law Group on

Federal prosecutors enjoy flipping through the United States Criminal Code, 18 U.S.C. §§ 1 et seq., to pick out tools to charge defendants.  Over the last ten years, DOJ’s reliance on criminal charges in FCPA cases has...more

The Volkov Law Group

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

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The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals.  ...more

The Volkov Law Group

FINRA Reminds Broker-Dealers on Importance of Compliance with New AML Rules

The Volkov Law Group on

The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements.  There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will...more

Vinson & Elkins LLP

Founder and Operator of Bitcoin “Mixer” Pleads Guilty to Money Laundering Conspiracy

Vinson & Elkins LLP on

Larry Dean Harmon, the founder and operator of Helix, a darknet-based cryptocurrency “mixer” or “tumbler,” recently admitted that Helix partnered with darknet marketplaces to provide bitcoin money laundering services for...more

Cadwalader, Wickersham & Taft LLP

DOJ Casts the FCPA Spotlight on Brazil-Related Enforcement

On May 25, 2021, the U.S. Department of Justice (“DOJ”) unsealed an indictment charging two Austrian citizens, Peter Weinzierl (“Weinzierl”) and Alexander Waldstein (“Waldstein”), for their roles in a scheme to launder...more

The Volkov Law Group

The Transformative Role of “National AML Priorities” for Compliance in the AML Act of 2020

The Volkov Law Group on

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

K2 Integrity

Federal Agencies Clarify Application of Model Risk Management Guidance to BSA/AML Compliance and Request Information from Industry

K2 Integrity on

On April 9, 2021, U.S. federal regulators issued an Interagency Statement addressing the application of existing model risk management guidance (MRMG) to systems or models used by banks to comply with Bank Secrecy Act (BSA)...more

Orrick, Herrington & Sutcliffe LLP

The Anti‐Money Laundering Act of 2020

On January 1, 2021, Congress enacted a broad range of anti-money laundering (“AML”) reforms within the Anti-Money Laundering Act of 2020 (the “AML Act”), as part of the National Defense Authorization Act for Fiscal Year 2021...more

Cadwalader, Wickersham & Taft LLP

The Anti-Money Laundering Act of 2020: New Challenges for Financial Institutions, Their Employees and Customers, and (Nearly)...

On January 1, 2021, Congress enacted the Anti-Money Laundering Act of 2020 (the “Act”). As part of the National Defense Authorization Act for Fiscal Year 2021, the Act creates a broad range of new anti-money laundering...more

Orrick, Herrington & Sutcliffe LLP

AML Enforcement Is a Key Tool to Combat Cryptocurrency Crimes

On October 8, 2020, the U.S. Attorney General’s Cyber-Digital Task Force released its Cryptocurrency Enforcement Framework. The Framework makes clear that, in addition to prosecuting bad actors who use cryptocurrency to...more

Orrick, Herrington & Sutcliffe LLP

The CFTC Begins Policing AML Enforcement

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

Herbert Smith Freehills Kramer

DOJ Cyber-Digital Task Force Releases Cryptocurrency Enforcement Framework

Building off a 2018 alert outlining cyber threats generally, and following the federal indictment for money laundering of the founders of the offshore cryptocurrency exchange BitMEX, on Oct. 8, 2020, the U.S. Department of...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Seeks Public Comment on Proposed Changes to Regulations Enforcing the Bank Secrecy Act

Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more

Foodman CPAs & Advisors

Fraud is Everywhere. The IRS is looking for it and the Forensic Accountants are right behind them

The Internal Revenue Manual defines fraud as a “deception by misrepresentation of material facts or silence when good faith requires expression, which results in material damage to one who relies on it and has the right to...more

Orrick, Herrington & Sutcliffe LLP

Record Anti-Money Laundering Fine Imposed on Swedbank

I. Background - Sweden’s financial supervisory authority (“SFSA”) recently fined Swedbank AB a record 4 billion Swedish kronor (approximately $386 million) for deficiencies in its anti-money laundering (“AML”) processes...more

Orrick, Herrington & Sutcliffe LLP

Former Bank Executive Assessed $450,000 Penalty for Failure to Prevent Anti-Money Laundering Violations at Bank

On March 4, 2020, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) assessed a civil monetary penalty of $450,000 against Michael LaFontaine, the former Chief Operational Risk Officer and...more

The Volkov Law Group

United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures

The Volkov Law Group on

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

Ballard Spahr LLP

Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key...

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First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more

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