On March 9, the European Parliament (“Parliament”) voted overwhelmingly to limit citizenship-by-investment (“CBI”) programs in the European Union. The vote, formally adopting a report by Sophie Int’ Veld, a Dutch Member of...more
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
Related Money Laundering Case Relying on ATM Cash-Outs and BEC Schemes Also Unsealed -
On February 17, the Department of Justice unsealed a sprawling indictment against three members of North Korea’s military intelligence...more
In the rainforests of Guatemala, Honduras and Nicaragua, the fires often start when drug traffickers try to clear large swaths of land. Due to the dry bush and lack of rainfall, the flames often spread out of control, but in...more
In the past month, the Government Accountability Office (“GAO”), a non-partisan legislative agency that monitors and audits government spending and operations, has issued a series of reports urging banking regulators and...more
Case Sheds Light on Latest Methods to Evade Detection: “Peeling” Chains -
On March 2, the U.S. government sanctioned and indicted two Chinese nationals for helping North Korea launder nearly $100 million in stolen...more
3/12/2020
/ Bitcoin ,
Brokers ,
China ,
Civil Forfeiture ,
Corruption ,
Criminal Conspiracy ,
Criminal Prosecution ,
Cryptocurrency ,
Currency Exchange ,
Financial Crimes ,
Foreign Nationals ,
Hackers ,
Money Laundering ,
Money Transmitter ,
North Korea ,
Sanctions ,
Virtual Currency ,
White Collar Crimes ,
Wire Fraud
On August 6, the U.S. Court of Appeals for the District of Columbia kept in place $50,000-per-day fines on three Chinese banks—whose identities are redacted—for refusing to comply with subpoenas issued by the Department of...more
8/9/2019
/ Anti-Money Laundering ,
Appeals ,
Department of Justice (DOJ) ,
Economic Sanctions ,
Financial Institutions ,
Financial Records ,
Financial Transactions ,
Foreign Banks ,
Money Laundering ,
National Security ,
North Korea ,
Patriot Act ,
Subpoenas
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
6/20/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Regulatory Requirements ,
Transparency
“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
1/30/2019
/ BSA/AML ,
Dark Web ,
Digital Assets ,
Financial Crimes ,
Financial Transactions ,
FinCEN ,
Mobile Apps ,
Money Laundering ,
Money Services Business ,
Money Transmitter ,
Online Gaming ,
Regulatory Standards ,
Video Games ,
Virtual Currency
Second Post in a Two-Part Series -
Opinion Stresses Importance of Narrative Sections and Supporting Documentation for SARs -
In our first post in this series, we discussed the Securities and Exchange Commission’s...more
12/26/2018
/ Broker-Dealer ,
Enforcement Actions ,
Failure-to-File ,
Filing Requirements ,
Financial Services Industry ,
Market Manipulation ,
Money Laundering ,
Penny Stocks ,
Securities and Exchange Commission (SEC) ,
Securities Violations ,
Suspicious Activity Reports (SARs)
On August 29, the Wall Street Journal reported (paywall) a story that other news outlets later have picked up: the Department of Justice (“DOJ”) is investigating whether Jho Low, a Malaysian businessman at the center of the...more
On February 23, the Financial Action Task Force (“FATF”) signaled that the inter-governmental body “will step up its efforts in monitoring the use of cryptocurrencies in money laundering.” ...more
3/2/2018
/ Anti-Money Laundering ,
Banking Sector ,
Bitcoin ,
Cryptocurrency ,
Digital Currency ,
FATF ,
G20 ,
Initial Coin Offering (ICOs) ,
Money Laundering ,
Regulatory Oversight ,
Risk Management ,
Token Sales ,
Virtual Currency
On June 29, dual trial verdicts in the Southern District of New York paved the way for the government to seize 650 Fifth Avenue, a 36-story building in Manhattan valued at up to $1 billion (“the Property”). The defendants,...more
On June 5, the SEC filed suit against Salt Lake City-based Alpine Securities, Corp. (“Alpine”). The complaint, filed in the Southern District of New York, alleges that the broker-dealer ran afoul of AML rules by “routinely...more
On Monday, the state of Florida moved a step closer towards amending its money laundering statute to include the nefarious use of bitcoin and other virtual currencies. The bill, H.B. 1379, has sailed through a committee vote...more
Banks stand to advance the fight against human trafficking and modern slavery by reporting suspicious transactions and other financial activity that raise red flags, according to a report on March 15, 2017. Published by the...more
The Philippines has been identified by the U.S. as a “major money-laundering country” in the 2017 International Narcotics Control Strategy Report (“Report”), published this month. The country now joins 87 others as one “whose...more
Despite the staggering $8 billion figure estimated to be spent on global compliance in 2017, U.S.-based rules regarding Anti-Money Laundering (“AML”) and Combating the Financing of Terrorism (“CFT”) remain anchored in their...more
2/22/2017
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Bitcoin ,
Blockchain ,
Digital Currency ,
Distributed Ledger Technology (DLT) ,
Financial Institutions ,
Money Laundering ,
Technology ,
Terrorism Funding ,
Terrorist Financing ,
Terrorist Financing Regulations ,
Virtual Currency
The Executive Vice President of Venezuela, Tareck Zaidan El Aissami Maddah (El Aissami), was designated on Monday by the U.S. Department of Treasury as a Specially Designated Narcotics Trafficker under the Foreign Narcotics...more
2/15/2017
/ Criminal Investigations ,
Foreign Narcotics Kingpin Designation Act ,
Foreign Narcotics Kingpin Sanctions ,
Foreign Official ,
Government Officials ,
Money Laundering ,
Narcotics ,
Office of Foreign Assets Control (OFAC) ,
U.S. Treasury ,
Venezuela ,
White Collar Crimes
The founders of Panamanian law firm Mossack Fonseca were arrested on Saturday, following their indictment on money-laundering charges allegedly tied to the ever-widening Petrobas corruption scandal in Brazil.
Kenia...more
2/14/2017
/ Brazil ,
Bribery ,
Corruption ,
Criminal Investigations ,
Indictments ,
Kickbacks ,
Money Laundering ,
Mossack Fonseca ,
Offshore Banks ,
Offshore Funds ,
Oil & Gas ,
Panama ,
Panama Papers ,
Petrobras ,
Tax Evasion ,
Tax Shelters
In part two of our review of the 2016 developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues, we discuss four additional key...more
2/7/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
Bitcoin ,
BSA/AML ,
Civil Forfeiture ,
Currency Transaction Reports (CTR) ,
Digital Currency ,
Financial Institutions ,
Forfeiture ,
Money Laundering ,
Virtual Currency
Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more
2/7/2017
/ Bitcoin ,
Department of Justice (DOJ) ,
Digital Currency ,
Enforcement Actions ,
Financial Institutions ,
Financial Services Industry ,
Internal Revenue Code (IRC) ,
IRS ,
John Doe Investigation ,
Money Laundering ,
Summons ,
Swiss Banks ,
Tax Evasion ,
Technology ,
Virtual Currency
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