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United States “Beats” Switzerland as a Perceived Global Haven for Money Laundering and Tax Evasion

The Cayman Islands Receive “Top Honors.”  But, Global Financial Transparency is Reportedly Improving in General - The United States has overtaken Switzerland as a financial secrecy haven, according to the latest rankings –...more

Should the Financial Industry Be Detecting Future Mass Shooters?

The United States continues to be plagued by mass shootings, which appear to be increasing in both frequency and lethality.  Certain businesses have reacted by adjusting their business models, such as the recent decision by...more

GAO Urges Further Assessment of Derisking Concerns

The U.S. Government Accountability Office (“GAO”) issued a statement earlier this week regarding testimony before the U.S. House of Representatives Subcommittee on Financial Institutions and Consumer Credit Committee on...more

Continued Individual Liability Under the Bank Secrecy Act: The SEC Targets Two AML Compliance Officers and One CEO for Alleged...

A recent anti-money laundering (“AML”) enforcement action reminds us of the increasing risk of individual liability for alleged violations of the Bank Secrecy Act (“BSA”), a key issue about which we have blogged....more

Uniform Act to Regulate Virtual Currency Businesses Ready for State Adoption

A new proposed law to create a statutory framework for regulating persons engaging in virtual-currency business activity, the Uniform Regulation of Virtual-Currency Businesses Act (URVCBA), has been approved by the Uniform...more

Marijuana Enforcement: DOJ Cole Memo Up in Smoke

Attorney General Sessions Announces Rescission of Obama Administration Policies on Marijuana Enforcement; Financial Institutions Lose Grounds to Permit Financial Transactions with Marijuana Businesses....more

Court Enforces — Partially — IRS “John Doe” Summons Served on Virtual Currency Exchanger

Last week, a federal magistrate judge in the Northern District of California granted in part and denied in part a motion by the IRS to enforce a “John Doe” summons served on Coinbase, Inc., which operates a virtual currency...more

2016 Year End Review: Virtual Currency: DOJ and IRS Broadly Seek Virtual Currency Account User Information

Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more

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