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
Authorities Begin to Focus on Individual Responsibility -
This week, Danish prosecutors charged Thomas Borgen, the former chief executive officer of Danske Bank, for his involvement in the money laundering scandal arising...more
The Financial Crimes Enforcement Network (FinCEN) released prepared remarks delivered by FinCEN director, Kenneth A. Blanco, at the Securities Industry and Financial Markets Association (SIFMA) Anti-Money Laundering (AML) &...more
2/7/2019
/ BSA/AML ,
Cooperative Compliance Regime ,
Employee Training ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Internal Controls ,
Money Laundering ,
Policy Statement ,
Regulatory Agenda ,
Terrorist Financing Regulations
This week Danske Bank released a report detailing the results of its much anticipated internal investigation into allegations of money laundering perpetrated in its Estonian branch. ...more
9/21/2018
/ Banking Sector ,
Corruption ,
Estonia ,
EU ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
Internal Controls ,
Money Laundering ,
Popular ,
Suspicious Activity Reports (SARs) ,
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)
A federal appeals court recently decided that a plaintiff could not assert a claim against the issuer of a reverse mortgage for breach of regulations issued by the U.S. Department of Housing and Urban Development (HUD), when...more
8/9/2016
/ Banking Sector ,
Breach of Contract ,
Financial Institutions ,
Fraudulent Concealment ,
Fraudulent Inducement ,
HECM ,
HUD ,
Liens ,
Mortgage Lenders ,
Mortgages ,
Real Estate Market ,
Reverse Mortgages ,
Summary Judgment ,
Written Agreements