Second Post in a Two-Post Series -
On March 19, 2020, Swedbank received its first sanction at the conclusion of parallel investigations by Swedish and Estonian authorities for its role in the seemingly non-stop Anti-Money...more
Danske Bank: “If we’re going down, you’re coming with us.” -
First Post in a Two-Post Series -
On March 19, 2020, Swedbank received the first of what will likely be multiple sanctions regarding alleged deficiencies in...more
On February 25, 2020, the Tenth Circuit Court of Appeals upheld the dismissal of shareholders’ securities-fraud class action against the Western Union Company (“Western Union”) and several of its current and former executive...more
3/2/2020
/ Aiding and Abetting ,
Anti-Fraud Provisions ,
BSA/AML ,
Class Action ,
Danske Bank ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Derivative Suit ,
Enforcement Actions ,
Failure to Comply ,
Federal Trade Commission (FTC) ,
Financial Transactions ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Misleading Statements ,
Pleading Standards ,
Popular ,
PSLRA ,
Public Statements ,
Regulatory Violations ,
Scienter ,
Securities Fraud ,
Shareholder Litigation ,
Stock Prices ,
Suspicious Activity Reports (SARs) ,
Western Union ,
Wire Fraud
Bank Accused of Being Asleep at the AML-CTF Switch -
On November 20, 2019, AUSTRAC, Australia’s anti money-laundering (“AML”) and counter-terrorism financing (“CTF”) regulator, initiated an action in the Federal Court of...more
12/2/2019
/ AML/CFT ,
Anti-Money Laundering ,
AUSTRAC ,
Australia ,
Child Abuse ,
Corruption ,
Counter-Terrorist ,
Cross-Border Transactions ,
Enforcement Actions ,
Exploitation ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Payment Processors ,
Regulatory Violations ,
Retail Banks ,
Risk Mitigation ,
Service Agreements ,
Statutory Violations ,
Terrorist Financing Regulations
On October 1st, the Office of the Comptroller of the Currency (OCC) published the Fiscal Year 2020 Bank Supervision Operating Plan (“FY 2020 Plan”). ...more
10/10/2019
/ Anti-Money Laundering ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Cybersecurity ,
Innovative Technology ,
Interest Rate Adjustments ,
Libor ,
Money Laundering ,
OCC ,
Supervision ,
Supervisory Guidance ,
Underwriting
We regularly blog about the conflict between state and federal law related to cannabis and the uncertainty regarding how federal criminal and Bank Secrecy Act (“BSA”) law will, or will not, be enforced against financial...more
8/22/2019
/ Bank Secrecy Act ,
BSA/AML ,
Decriminalization of Marijuana ,
Dispensaries ,
Financial Institutions ,
Financial Services Industry ,
Legislative Agendas ,
Marijuana ,
Marijuana Related Businesses ,
NCUA ,
Proposed Legislation ,
Suspicious Activity Reports (SARs)
Second Post in a Two-Post Series on the ILLICIT CASH Act -
A discussion draft of legislation recently introduced in the Senate, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal...more
6/28/2019
/ AML/CFT ,
Anti-Money Laundering ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Legislative Agendas ,
Money Laundering ,
No-Action Letters ,
Proposed Legislation ,
Safe Harbors ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding ,
Terrorist Financing Regulations
The state-legal marijuana industry in the United States continues to grow – as does support for it. Ten states and Washington, D.C. have legalized recreational adult use and 23 other states allow some form of medical...more
The Danske Bank money laundering scandal continues to reveal its many permutations and confirm its status as the largest money laundering case in history....more
Former Bankers Allegedly Concealed “Master of Kickbacks” from Internal Compliance Department -
A detailed indictment unsealed on January 3 in the Eastern District of New York alleges that former Credit Suisse bankers, a...more
NYDFS Action Highlights the Need for Good Monitoring – and Good Consultants -
In part one of this two-part post, we provided some practical tips for financial institutions to increase the chances that their Anti-Money...more
11/8/2018
/ Anti-Money Laundering ,
BSA/AML ,
Enforcement Actions ,
Failure to Comply ,
Financial Institutions ,
Financial Services Industry ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Money Laundering ,
NYDFS ,
Office of Foreign Assets Control (OFAC) ,
Regulatory Violations
According to the Financial Flow from Human Trafficking report recently published by the Financial Action Task Force (“FATF”) and the Asia/Pacific Group on Money Laundering, human trafficking is estimated to generate $150.2...more
Canada’s Liberal government recently introduced a bill, known as C-74, that would allow for a type of deferred prosecution agreement called a “remediation agreement” for alleged violations of Canada’s foreign bribery law, the...more