On June 14, 2024, President Biden declared June 15th World Elder Abuse Awareness Day. In honor of the day, the Financial Crimes Enforcement Network (FinCEN) reminded financial institutions (FIs) to remain vigilant in...more
6/24/2024
/ Bank Secrecy Act ,
BSA/AML ,
Consumer Financial Products ,
Elder Abuse ,
Exploitation ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Reporting Requirements ,
Scams ,
Suspicious Activity Reports (SARs) ,
Vulnerability Assessments
The Financial Crimes Enforcement Network (“FinCEN”) recently issued a Financial Trend Analysis (“Analysis”) focusing on patterns and trends identified in Bank Secrecy Act (“BSA”) data linked to Elder Financial Exploitation...more
5/2/2024
/ Bank Secrecy Act ,
BSA/AML ,
Elder Abuse ,
Exploitation ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
New Guidance ,
Popular ,
Scams ,
Suspicious Activity Reports (SARs)
Following Russia’s invasion of Ukraine, the Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) issued a joint alert and a supplemental alert (the...more
9/18/2023
/ Anti-Money Laundering ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Russia ,
Suspicious Activity Reports (SARs)
The Financial Crimes Enforcement Network (“FinCEN”) recently complied with two important deadlines under the Anti-Money Laundering Act (“AML Act”) — issuing national priorities for AML and countering the financing of...more
Much has occurred in the last two months regarding the relationship between financial institutions and Marijuana-Related Businesses, or MRBs. In this post, we discuss three major developments, all of which share a complex...more
On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more
12/5/2019
/ Agribusiness ,
Anti-Corruption ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
BSA/AML ,
Cannabis Products ,
Consumer Financial Products ,
Controlled Substances ,
Controlled Substances Act ,
Debit and Credit Card Transactions ,
Decriminalization of Marijuana ,
Deregulation ,
Farm Bill ,
FDIC ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Hemp ,
Hemp Cultivation ,
Interstate Commerce ,
Marijuana ,
Marijuana Cultivation ,
Marijuana Related Businesses ,
New Guidance ,
OCC ,
Regulatory Oversight ,
Regulatory Requirements ,
Small Business Loans ,
Suspicious Activity Reports (SARs) ,
USDA
First Post in a Two-Part Series -
How do financial institutions get in trouble with their regulators? Recent AML enforcement actions suggest that the following two failures are at the heart of most of these actions: (1)...more
11/2/2018
/ Anti-Money Laundering ,
Filing Requirements ,
Financial Institutions ,
Information Sharing ,
Internal Controls ,
Policies and Procedures ,
Regulatory Requirements ,
Risk Management ,
Suspicious Activity Reports (SARs) ,
Tone At The Top ,
Transaction Monitoring
Congress enacted the safe harbor provision of the Bank Secrecy Act (BSA), codified at 31 U.S.C. §5318(g)(3)(A), to shield financial institutions, their officers and employees from civil liability for reporting known or...more
On June 12, 2018, FinCEN issued an “Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators” to highlight the connection between corrupt senior foreign political...more
6/19/2018
/ Corruption ,
Exploitation ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Foreign Official ,
Human Rights ,
Money Laundering ,
Offshore Companies ,
PEP ,
Shell Corporations ,
Suspicious Activity Reports (SARs) ,
White Collar Crimes
2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more
2/3/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Casinos ,
Consumer Lenders ,
Customer Due Diligence (CDD) ,
FATF ,
Financial Institutions ,
FinCEN ,
Fines ,
Gambling ,
Gaming ,
Geographic Targeting Order ,
Money Laundering ,
Mortgage Lenders ,
Mortgages ,
NYDFS ,
Offshore Funds ,
Panama Papers ,
Popular ,
Real Estate Market ,
Suspicious Activity Reports (SARs) ,
Tax Evasion