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 June 23, 2022, the Office of the Comptroller of the Currency (OCC) released its Semiannual Risk Perspective (SRP) for spring 2022. In the SRP, the OCC opines on its current safety and soundness concerns for banks under...more
October is National Cybersecurity Awareness Month, and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and Office of Foreign Assets Control (“OFAC”) kicked off the month by issuing two...more
10/8/2020
/ Bank Secrecy Act ,
BSA/AML ,
Cyber Crimes ,
Cybersecurity ,
Financial Institutions ,
FinCEN ,
International Emergency Economic Powers Act (IEEPA) ,
Office of Foreign Assets Control (OFAC) ,
Privacy Concerns ,
Ransomware ,
Suspicious Activity Reports (SARs)
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
Last week, President Donald Trump issued an Executive Order banning “all transactions” and “dealings” by any individual or entity in the United States that involve “any digital currency, digital coin, or digital token” issued...more
3/28/2018
/ BSA/AML ,
Digital Currency ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
Money Laundering ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela ,
Virtual Currency
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
PANA Issues Recommendations to European Parliament: Tougher Enforcement, Greater Transparency, Improved Information Sharing and Prohibitions Against Outsourcing of Customer Due Diligence....more
10/27/2017
/ Banking Sector ,
BSA/AML ,
Customer Due Diligence (CDD) ,
EU ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Offshore Funds ,
Panama Papers ,
Popular ,
Regulatory Oversight ,
Suspicious Activity Reports (SARs) ,
Tax Avoidance ,
Tax Evasion