How effective is the current framework for filing Suspicious Activity Reports, or SARs? The AML Act mandates that federal law enforcement agencies provide statistics to assist Congress, regulators, and financial institutions...more
On June 3, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advance Notice of Proposed Rulemaking (“ANPRM”) that seeks public comment on the implementation of a “no-action letter” process at FinCEN. The...more
Lawmakers Targeted “Gatekeeper” Professions Following the Pandora Papers Leak -
Motivated by revelations contained in the recently-released Pandora Papers, on October 6, 2021, four U.S. Representatives – Tom Malinowski...more
Case Presages Mandatory BSA Obligations for Antiquities Dealers under the AML Act -
In the midst of the invasion of Iraq and the subsequent civil instability, thousands of cultural artifacts were stolen from the National...more
Treasury Offers Something for Everyone to Comply With: Trades and Businesses, Banks, Crypto Exchangers and Individuals -
On May 21, 2021, the U.S. Department of Treasury (“Treasury”) released its American Families Plan Tax...more
On October 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a COVID-19-related Advisory “to alert financial institutions to unemployment insurance (“UI”) fraud observed during the COVID-19 pandemic.” It is the...more