News & Analysis as of

Anti-Money Laundering White Collar Crimes Financial Institutions

Skadden, Arps, Slate, Meagher & Flom LLP

EU Updates Sanctions Best Practices, Clarifying Ownership Threshold for Asset Freeze Restrictions

The Council of the European Union (Council) has updated its EU Best Practices for the Effective Implementation of Restrictive Measures. Published on 3 July 2024, the new version clarifies the threshold for the ownership test...more

The Volkov Law Group

FinCEN Issues Proposed Rule to Strengthen and Modernize Financial Institutions’ AML/CFT Programs

The Volkov Law Group on

On June 28, 2024, the Financial Crimes Enforcement Network released a notice of proposed rulemaking. The purpose of the proposed rule is to strengthen and modernize Anti-Money Laundering and Countering the Financing of...more

The Volkov Law Group

European Council Officially Adopts New AML/CFT Package

The Volkov Law Group on

On May 30, 2024, following passage by the European Parliament in late April, the European Council officially adopted a set of rules that modernizes and harmonizes money laundering and terrorist financing (“AML/CFT”)...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Pilot Program Promises Non-Prosecution Agreements to Individuals Reporting Fraud, Bribery and Other Corporate Crimes

On April 15, 2024, the Department of Justice’s (DOJ’s) Criminal Division unveiled a new Pilot Program on Voluntary Self-Disclosures for Individuals that offers non-prosecution agreements (NPAs) to individuals who voluntarily...more

Cadwalader, Wickersham & Taft LLP

FinCEN Proposes New Rule Requiring AML Compliance Programs for Investment Advisers

On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more

J.S. Held

INDEPTH FEATURE: Anti-Money Laundering 2024

J.S. Held on

Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more

Ballard Spahr LLP

Former Bank Compliance Chief Seeks Appellate Review of OCC Administrative Enforcement Proceeding Dismissal

Ballard Spahr LLP on

In an unusual move, Laura Akahoshi, former Rabobank (the “Bank”) Chief Compliance Officer (“CCO”), filed on July 6, 2023 an opposition to the Office of the Comptroller of the Currency’s (“OCC”) dismissal of its own...more

Perkins Coie

Mapping Future Enforcement in US Gaming Law Based on Recent UK Enforcement

Perkins Coie on

Regulated gaming is booming in the United States. This is particularly true of newer forms of gambling, such as skill games, fantasy sports, and social casino games played on the internet and mobile applications. In fact,...more

The Volkov Law Group

FinCEN Issues Final Rule for Beneficial Ownership Reporting

The Volkov Law Group on

The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rules implementing the beneficial ownership reporting requirements pursuant to the bipartisan Corporate Transparency Act (“CTA”).  The...more

K2 Integrity

Federal Agencies Clarify Application of Model Risk Management Guidance to BSA/AML Compliance and Request Information from Industry

K2 Integrity on

On April 9, 2021, U.S. federal regulators issued an Interagency Statement addressing the application of existing model risk management guidance (MRMG) to systems or models used by banks to comply with Bank Secrecy Act (BSA)...more

The Volkov Law Group

The Coming AML Enforcement Storm

The Volkov Law Group on

Blog after blog, commentator after commentator, and everyone else who has an opinion has been repeating the same message – the Biden Administration is going to increase enforcement risks....more

Foodman CPAs & Advisors

¿Cómo Afectará a su Institución Financiera la Capacitación de Examinadores requerida bajo la Ley ALD del 2020 (El Acto)?

La sección 6307 del Acto (“AML ACT of 2020”) requiere la capacitación anual para Examinadores sobre la lucha contra el lavado de dinero y el financiamiento del terrorismo. La capacitación debe realizarse en consulta con...more

K2 Integrity

New U.S. Law’s Impacts on Non-U.S. Financial Institutions

K2 Integrity on

The U.S. Anti-Money Laundering Act of 2020 (AML Act) became law on January 1 when the United States Congress passed the broader National Defense Authorization Act for 2021 over a presidential veto. Although it is a U.S. law,...more

Orrick, Herrington & Sutcliffe LLP

The Anti‐Money Laundering Act of 2020

On January 1, 2021, Congress enacted a broad range of anti-money laundering (“AML”) reforms within the Anti-Money Laundering Act of 2020 (the “AML Act”), as part of the National Defense Authorization Act for Fiscal Year 2021...more

Arnall Golden Gregory LLP

“Modernized” and “Improved” Systems and Processes: How the Anti-Money Laundering Act of 2020 Changes the Landscape for Government...

With bipartisan support and overriding (for the first and only time during the Trump presidency) a presidential veto, Congress passed the National Defense Authorization Act (“NDAA”) on January 1, 2021.1  As part of the NDAA,...more

Cadwalader, Wickersham & Taft LLP

The Anti-Money Laundering Act of 2020: New Challenges for Financial Institutions, Their Employees and Customers, and (Nearly)...

On January 1, 2021, Congress enacted the Anti-Money Laundering Act of 2020 (the “Act”). As part of the National Defense Authorization Act for Fiscal Year 2021, the Act creates a broad range of new anti-money laundering...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Enacts Historic Legislation To Strengthen Anti-Money Laundering and Counterterrorist Financing Legal Framework

On January 1, 2021, the United States Congress overrode the president’s veto to enact the 2021 National Defense Authorization Act (the NDAA), which, aside from allocating the annual defense budget, includes the Anti-Money...more

Cohen & Gresser LLP

Pulling Back the Curtain: Congress Establishes a Beneficial Ownership Registry for U.S. and Foreign Businesses

Cohen & Gresser LLP on

On January 1, 2021, Congress overrode President Trump’s veto, passing into law the annual National Defense Authorization Act for Fiscal Year 2021 (“NDAA”). ...more

Morgan Lewis

Congress Creates Enhanced Whistleblower Program for AML Violations

Morgan Lewis on

As part of a modernization of the nation’s anti-money laundering regime, the Anti-Money Laundering Act of 2020 creates enhanced whistleblower rewards that are likely to lead to increased enforcement action....more

White & Case LLP

Draft regulation with provisional simplification of KYC measures for the banking sector in Mexico

White & Case LLP on

On Sunday June 21, 2020, the Mexican Banking and Securities Commission ("CNBV") ?in charge of the anti-money laundering and counter-financing of terrorism ("AML/CFT") supervision of the banking sector in Mexico? communicated...more

Orrick, Herrington & Sutcliffe LLP

Record Anti-Money Laundering Fine Imposed on Swedbank

I. Background - Sweden’s financial supervisory authority (“SFSA”) recently fined Swedbank AB a record 4 billion Swedish kronor (approximately $386 million) for deficiencies in its anti-money laundering (“AML”) processes...more

Orrick, Herrington & Sutcliffe LLP

Former Bank Executive Assessed $450,000 Penalty for Failure to Prevent Anti-Money Laundering Violations at Bank

On March 4, 2020, the Financial Crimes Enforcement Network of the U.S. Treasury Department (“FinCEN”) assessed a civil monetary penalty of $450,000 against Michael LaFontaine, the former Chief Operational Risk Officer and...more

The Volkov Law Group

United Bank Risk Officer Agrees to $450k Penalty for AML Compliance Failures

The Volkov Law Group on

Compliance professionals face extraordinary risks – not just for the enterprise but personal risks.  CCOs should not panic or overreact when the government brings an enforcement action against a compliance officer for a...more

Ballard Spahr LLP

Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key...

Ballard Spahr LLP on

First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more

Thomas Fox - Compliance Evangelist

The Wild Wild West and ComTech

Compliance has been pushed more to the forefront in anti-money laundering (AML). As banking institutions, financial institutions and the financial services industries continue to tighten and strengthen AML controls, criminals...more

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