On August 8, 2023, the American Bar Association (“ABA”) House of Delegates voted overwhelmingly (216–102) to pass Revised Resolution 100 (the “Resolution”), which in turn revised ABA Model Rule of Professional Conduct 1.16...more
On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the Digital Asset Anti-Money Laundering Act (the “Act”), legislation aimed at closing...more
8/14/2023
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
CFTC ,
Corporate Transparency Act ,
Digital Assets ,
FBAR ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Money Services Business ,
NDAA ,
Proposed Legislation ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC)
Legislation Targets Unhosted Wallets, Validators and Digital Asset ATMs -
On July 28th, Senators Elizabeth Warren (D-Mass), Roger Marshall (R-Kan.), Joe Manchin (D-W.Va.) and Lindsey Graham (R-S.C.), reintroduced the...more
8/11/2023
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Corporate Transparency Act ,
Cryptoassets ,
Cryptocurrency ,
Cyber Crimes ,
Digital Assets ,
Digital Wallets ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Money Services Business ,
Proposed Legislation ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC)
On September 13, the United States Attorney’s Office for the Eastern District of New York announced that defendant Hanan Ofer pleaded guilty to “failing to maintain an effective anti-money laundering program.” Ofer and his...more
On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. ...more
On July 20, 2022, the Connecticut Department of Banking (the “Department”) issued a Consumer and Industry Advisory on Money Transmission (the “Advisory”). The Department believes the Advisory was necessary for two reasons. ...more
Global AML Compliance Faces Challenges Relating to Regulator Expertise, the Travel Rule, Decentralized Finance, and “Regulator Shopping”...more
European Commission Proposes EU-Level Supervisory Authority and Cryptocurrency Travel Rule -
European Banking Authority Offers New Guidelines on AML Compliance Officers -
Just as the United States has expanded...more
Agenda Highlights Intersection of National Security, Corruption and Anti-Money Laundering -
On June 3, 2021, President Biden unveiled a National Security Study Memorandum entitled Memorandum on Establishing the Fight...more
As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) contains major changes to the Bank Secrecy Act (“BSA”), coupled with other changes relating to money laundering, anti-money laundering (“AML”),...more
On November 5, 2020, the Council of the European Union approved a new action plan to strengthen anti-money laundering and combatting terrorism financing across the EU. The Action Plan, “an Action Plan for a comprehensive...more
New York State Encourages Banking for State-Licensed Medical Marijuana Businesses – Whereas a Maine Company Runs Into Trouble, Despite State Law Legalizing Medical Marijuana....more
8/16/2018
/ Anti-Money Laundering ,
BSA/AML ,
Cole Memorandum ,
Controlled Substances ,
Decriminalization of Marijuana ,
Dispensaries ,
Federal v State Law Application ,
Financial Institutions ,
Financial Services Industry ,
Financial Transactions ,
Healthcare ,
Marijuana ,
Marijuana Related Businesses ,
Medical Marijuana ,
New Guidance ,
NYDFS ,
Regulatory Standards ,
Risk Management ,
State and Local Government
Late last week, the Financial Conduct Authority (“FCA”), the United Kingdom’s financial services regulator, imposed a $1.2 million (896,100 pound) fine on the UK division of India’s Canara Bank, an Indian state-owned bank,...more
As we blogged earlier this week, Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), in committee in the Senate. The CTIFA proposes the most substantial overhaul to the Bank...more
1/25/2018
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
Financial Regulatory Reform ,
Information Sharing ,
Legislative Agendas ,
Money Laundering ,
Patriot Act ,
Proposed Legislation ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), currently in committee in the Senate. The CTIFA proposes the most substantial overhaul to the Bank Secrecy Act (“BSA”) since...more
1/23/2018
/ Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Financial Regulatory Reform ,
FinCEN ,
Legal Entities ,
Legislative Agendas ,
Proposed Legislation ,
Risk Assessment ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
Terrorist Financing Regulations