On June 17, 2020, the Financial Conduct Authority (“FCA”), the non-governmental financial regulator in the United Kingdom, issued a Final Notice to Commerzbank London (the “Bank”), a branch of the large German business bank,...more
Examiners Should Focus on Risk, Not Technical Perfection -
On April 15, 2020, the Federal Financial Institutions Examination Council (“FFIEC”) released updates to the Bank Secretary Act/Anti-Money Laundering (“BSA/AML”)...more
In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more
3/5/2020
/ AML/CFT ,
Anti-Money Laundering ,
Broker-Dealer ,
BSA/AML ,
Currency Transaction Reports (CTR) ,
FATF ,
Financial Institutions ,
FinCEN ,
Foreign Investment ,
Geographic Targeting Order ,
Innovative Technology ,
Legal Representatives ,
Money Laundering ,
Natural Person Requirement ,
Real Estate Investments ,
Real Estate Market ,
Real Estate Transactions ,
Regulatory Requirements ,
Service Professionals ,
Title Insurance ,
U.S. Treasury ,
Virtual Currency
First in a Two-Post Series -
The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more
2/28/2020
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Casinos ,
Corruption ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Digital Assets ,
FATF ,
Financial Institutions ,
FinCEN ,
Foreign Correspondent Banking ,
Money Laundering ,
Money Services Business ,
Proposed Rules ,
Real Estate Transactions ,
Rulemaking Process ,
Securities Transactions ,
Strategic Enforcement Plan ,
Terrorism Funding ,
Terrorist Financing Regulations ,
Transparency ,
U.S. Treasury ,
Vulnerable Victims ,
White Collar Crimes
Incorporation Solidifies Customer Due Diligence as “Fifth Pillar” to BSA/AML Compliance Program -
May 11, 2018 was the much anticipated effective date for the Customer Due Diligence (“CDD”) Requirements for Financial...more
The Financial Crimes Enforcement Network (“FinCEN”) recently advised that a financial institution is not required to file a Suspicious Activity Report (“SAR”) based solely upon a customer’s inquiry into or participation in a...more
FinCEN recentlty announced entry of a $2 million assessment against Lone Star National Bank, a private bank operating out of Texas, for the bank’s allegedly willful violations of the Bank Secrecy Act (“BSA”) and inadequate...more
11/8/2017
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Due Diligence ,
Enforcement Actions ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Foreign Correspondent Banking ,
Mexico ,
Patriot Act ,
Regulatory Oversight ,
Suspicious Activity Reports (SARs)