This Article discusses the recent plea agreement between the United States and Danske Bank. It argues that the Department of Justice has advanced a new and evolving theory of liability for foreign banks that access the U.S....more
4/10/2023
/ Anti-Money Laundering ,
Bank Fraud ,
Banking Sector ,
Banks ,
Conspiracies ,
Criminal Conspiracy ,
Criminal Liability ,
Department of Justice (DOJ) ,
Financial Institutions ,
Foreign Banks ,
Fraud ,
Liability ,
Plea Agreements ,
Popular ,
Statutory Violations
On November 1, 2021, the President’s Working Group on Financial Markets (PWG) - along with the Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC) - published the Report on...more
11/16/2021
/ Anti-Money Laundering ,
Blockchain ,
CFTC ,
Cross-Border ,
Cryptocurrency ,
Exchange Rates ,
FDIC ,
FinCEN ,
FSOC ,
Information Reports ,
Legislative Agendas ,
OCC ,
Payment Systems ,
Prudential Regulation Authority (PRA) ,
Regulatory Agenda ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Stablecoins
On September 21, 2021, the US Treasury Department’s Office of Foreign Assets Control (“OFAC”) levied its first sanctions against a Russian-operated virtual currency exchange involved in ransomware payments and published an...more
9/24/2021
/ Advisory Opinions ,
AML/CFT ,
Anti-Money Laundering ,
Compliance ,
Cryptocurrency ,
Currency Exchange ,
Cybersecurity Information Sharing Act (CISA) ,
Economic Sanctions ,
FinCEN ,
Know Your Customers ,
Office of Foreign Assets Control (OFAC) ,
Ransomware ,
Russia ,
SDN List ,
U.S. Treasury ,
Virtual Currency
The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more
7/15/2021
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Biden Administration ,
Compliance ,
Cybersecurity ,
Drug Trafficking ,
Enforcement Priorities ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Human Trafficking ,
No-Action Letters ,
Nonbank Firms ,
Ransomware ,
Significant Transnational Criminal Organization ,
Terrorism Funding ,
Virtual Currency
Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more
2/12/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
NDAA ,
Patriot Act ,
Risk Assessment ,
Suspicious Activity Reports (SARs)