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FinCEN Seeks Comments on Modernizing the AML/CFT Regime

On December 14, the Financial Crimes Enforcement Network (“FinCEN”) issued a request for information (“RFI”), seeking comment on ways to “streamline, modernize, and update” the anti-money laundering (“AML”) and...more

FinCEN Solicits Comments on AML Rules for the Antiquities Trade

On September 23, the Financial Crimes Enforcement Network (“FinCEN”) issued an advance notice of proposed rulemaking (“ANPRM”) to solicit comment on questions related to the implementation of anti-money laundering (“AML”)...more

FATF Continues to Stress AML Risks From Virtual Asset Service Providers

Fourth and Final Post in a Series on the FATF Plenary Outcomes - As we have previously blogged, the Financial Action Task Force (“FATF”) held its fourth Plenary on June 21-25, inviting delegates from around the world to...more

FinCEN Proposes New Rule for “Unhosted” Virtual Currency Wallets

On December 18, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposal to impose on banks and money service businesses (“affected institutions”) a new set of rules for digital currency transactions involving...more

Joint Statement Clarifies Due Diligence Expectations for Politically Exposed Persons

Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more

FinCEN Director Blanco Addresses “Cyber Hygiene”

FinCEN Director Kenneth A. Blanco delivered prepared remarks on September 24 at the 2019 Federal Identity (FedID) Forum and Exposition in Tampa, Florida. Director Blanco summarized the topics of his remarks by stating the...more

Lawmakers Renew Effort to Overhaul AML Laws, Including Greater Beneficial Ownership Transparency

The Issue of Who Truly Runs and Owns Entities Contines to Gnaw at Congress and Law Enforcement - First Post in a Two-Post Series on the ILLICIT CASH Act - On June 10, a bipartisan group of lawmakers in the U.S. Senate...more

Popular Video Game Serves as a Reminder of Regulatory Risks of In-game/In-app Virtual Currencies

“V-bucks,” the in-game virtual value currency of the wildly popular video game, Fortnite, is reportedly being used to launder the proceeds of stolen credit cards....more

FinCEN Employee Charged with Unlawful Disclosure of SARs to Reporter

Charges Represent First Criminal Case Based Solely on Alleged Unauthorized SAR Disclosure - On October 17, the U.S. Attorney for the Southern District of New York (“SDNY”) announced the arrest of a senior employee at the...more

Beneficial Ownership Provision Stripped from Latest Draft of Counter Terrorism and Illicit Finance Act

Critics Bemoan Removal of Potential Weapon Against Shell Companies - Last week, and on the eve of a scheduled markup of the original bill in the House Financial Services Committee, a new draft of the Counter Terrorism and...more

Beyond Best Practices: Regulatory Compliance Now a Necessity in the Cryptocurrency Sector

As the value of bitcoin continues to soar (USD:BTC this past weekend exceeded $19,000.00:1), we thought that now would be a good time to emphasize the need to ensure regulatory compliance with the many federal and state AML...more

2016 Year in Review: Money Laundering (Part One)

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

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