News & Analysis as of

Anti-Corruption Anti-Money Laundering BSA/AML

Foodman CPAs & Advisors

FinCEN Final New Rules Close Loopholes in U.S. Financial System

On August 28, 2024, FinCEN Final New Rules were published that address vulnerabilities in the U.S. financial system and are part of an on going effort to combat illicit finance and protect U.S. national security, as well as...more

Cadwalader, Wickersham & Taft LLP

FinCEN Issues Beneficial Ownership Information “Access Rule”

On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule setting forth the circumstances under which beneficial ownership information reported to FinCEN pursuant to the Corporate...more

BakerHostetler

Treasury Revisits Past Rulemaking to Bring Investment Advisers Under AML Oversight

BakerHostetler on

In connection with the Biden Administration’s ongoing crackdown on corruption, tax havens, and illicit financing, on December 11, Treasury released a Fact Sheet on its “efforts to address the illicit finance and national...more

The Volkov Law Group

TD Bank Eats $225 Million Termination Fee After AML Failures Doom Merger

The Volkov Law Group on

How much is an effective Anti-Money Laundering (“AML”) Compliance Program Worth? For Toronto-Dominion Bank (“TD”), the answer is at least $225 million––the amount that TD must now pay to First Horizon Bank, after backing...more

Manatt, Phelps & Phillips, LLP

The Government’s New Strategy To Counter Corruption: What You Need To Know

On June 3, 2021, the White House issued a memorandum formally establishing the fight against corruption as a core national security interest. The memorandum directed the development of a presidential strategy to, among other...more

Jones Day

FinCEN Issues First U.S. Priorities for Anti-Money Laundering and Counter-Terrorism Financing

Jones Day on

On June 30, 2021, FinCEN announced the first set of government-wide AML/CFT Priorities, as required by the Anti-Money Laundering Act of 2020 ("AML Act"). Consistent with the National Strategy for Combating Terrorist and Other...more

Kohn, Kohn & Colapinto LLP

Congress Needs to Enact an Effective Ethics Agenda

Congress needs to implement an effective ethics agenda.  Important anti-corruption legislation has been sitting in various Senate and House committees awaiting action....more

A&O Shearman

Money laundering concerns prompt consultation on regulation of virtual asset service providers in Hong Kong

A&O Shearman on

(i) a licensing regime for virtual asset trading platforms in Hong Kong, including anti-money laundering obligations; (ii) a two-tier registration regime for dealers in precious metals and stones; and...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Seeks Public Comment on Proposed Changes to Regulations Enforcing the Bank Secrecy Act

Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Compliance in a Time of Crisis

Addressing the Evolving Risks - Warren Buffett said that “only when the tide goes out do you discover who’s been swimming naked.” Buffett was not talking about compliance programs in a time of crisis, but his wisdom applies...more

Ballard Spahr LLP

Financial Action Task Force Update: Statement on COVID-19’s Implications for AML Programs

Ballard Spahr LLP on

First Post in a Two-Post Series on Recent FATF Activity - Members presumably working from home, the Financial Action Task Force (“FATF”) was active last week, first issuing its 3rd Enhanced Follow-up Report & Technical...more

Foodman CPAs & Advisors

What is Next after BSA turns 50?

On 2/6/2020, the U.S. Department of the Treasury issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy).  The purpose of the 2020 Strategy is to...more

Foodman CPAs & Advisors

¿Su institución financiera utiliza un “Matrix” de enfoque basado en el riesgo de la OFAC?

El perfil de riesgo de la OFAC de una Institución Financiera se determina basado sus productos, servicios, clientes y ubicaciones geográficas.  Se requiere que un programa de cumplimiento OFAC de una Institución Financiera...more

Foodman CPAs & Advisors

Does your Financial Institution utilize OFAC’s Risk Based Approach Matrix?

A Financial Institution’s OFAC risk profile is determined based on its products, services, customers and geographic locations.  A Financial Institution’s OFAC compliance program is required to...more

Ballard Spahr LLP

Banking Regulators Ease SAR Reporting Requirements Applied to Hemp-Related Businesses

Ballard Spahr LLP on

On December 3, 2019, four federal agencies – the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Office of the...more

Ballard Spahr LLP

FinCEN Issues Advisory on Foreign Jurisdictions with AML Deficiencies

Ballard Spahr LLP on

On November 12, 2019, FinCEN issued its latest Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combatting the Financing of Terrorism Deficiencies and Relevant Actions by the...more

Thomas Fox - Compliance Evangelist

Baseball Moves Forward and the Advancement of Compliance Through ComTech

What have been some of the advancements in compliance this century? One of the key recent innovations has been the role of Artificial Intelligence (AI) in compliance going forward. LawTech had disrupted the legal profession...more

Ballard Spahr LLP

What the Basel AML Index Reveals About Global Money Laundering Risks

Ballard Spahr LLP on

Established in 2003, the Basel Institute is a not-for-profit Swiss foundation dedicated to working with public and private partners around the world to prevent and combat corruption, and is an Associated Institute of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - January 2019

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including DOJ guidance on the use of corporate monitors in criminal...more

The Volkov Law Group

Dig a Little Deeper: The Importance of Beneficial Ownership

The Volkov Law Group on

Companies interact with a large number of entities in the outside world – customers, third party intermediaries and vendors and suppliers to name the most significant ones. These relationships are the lifeblood of a company....more

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