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FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

United States V. Danske Bank: New Theory of Liability for Violation of US AML Standards

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

COVID-19: Federal Regulators Provide Limited AML Relief in Coronavirus Response, and Limited Support for the Use of Technology in...

In this alert, we summarize recent guidance from federal regulators and self-regulatory organizations - including the Financial Crimes Enforcement Network (FinCEN), the Office of Foreign Assets Control (OFAC), the Office of...more

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