News & Analysis as of

Bank Secrecy Act › Cybersecurity

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
Eversheds Sutherland (US) LLP

FinCEN and SEC propose Customer Identification Program requirements for investment advisers

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Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

Bracewell LLP

FINRA Facts and Trends: January 2024

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Welcome to the latest issue of Bracewell’s FINRA Facts and Trends, a monthly newsletter devoted to condensing and digesting recent FINRA developments in the areas of enforcement, regulation and dispute resolution. We dedicate...more

Davis Wright Tremaine LLP

FINRA’s 2024 Annual Regulatory Oversight Report: Select Observations

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FINRA recently published its 90-page 2024 Annual Regulatory Oversight Report (Report) providing member firms with insight into six primary topics: Financial Crimes, Crypto Asset Development, Firm Operations, Communications...more

Troutman Pepper

Federal Agencies Issue Access Rule to Beneficial Ownership Information Pursuant to the CTA

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On December 21, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Financial Crimes Enforcement Network (FinCen), the National Credit Union Administration, along with...more

Orrick, Herrington & Sutcliffe LLP

Treasury recommends strengthening DeFi AML/CFT supervision

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On April 6, the U.S. Treasury Department published a report on illicit finance risks in the decentralized finance (DeFi) sector, building upon Treasury’s other risk assessments, and continuing the work outlined in Executive...more

Orrick, Herrington & Sutcliffe LLP

FinCEN analyzes BEC threat patterns and trends in the real estate sector

Orrick, Herrington & Sutcliffe LLP on

On March 30, FinCEN released a Financial Trend Analysis examining threat patterns and trends identified in Bank Secrecy Act (BSA) data relating to business email compromise (BEC) in the real estate sector during 2020 and...more

BakerHostetler

US Crypto Exchange Consents to $100M DFS Settlement for AML Compliance Failures

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On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more

Harris Beach PLLC

New York Sends Clear Message Crypto Exchanges and Banks Must Meet AML Obligations

Harris Beach PLLC on

New York’s Department of Financial Services (“DFS”) recently announced a $100 million settlement with Coinbase, Inc., one of the world’s largest cryptocurrency exchanges, for Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”)...more

Ballard Spahr LLP

Privacy, Cybersecurity and Access to Beneficial Ownership Information: FinCEN Issues Notice of Proposed Regulations Under the...

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A Deep Dive Into FinCEN’s Latest Proposals Under the CTA - On December 16, the Financial Crimes Enforcement Network (“FinCEN”) issued a 54-page notice of proposed rulemaking (“NPRM”) regarding access by authorized recipients...more

Hogan Lovells

FinCEN analysis of BSA filings in 2021 reveals increased number and severity of ransomware attacks

Hogan Lovells on

The Financial Crimes Enforcement Network’s most recent financial trend analysis report on ransomware-related Bank Secrecy Act filings for 2021 reveals an increased number of ransomware attacks and that a substantial number of...more

Proskauer - Blockchain and the Law

New York Financial Regulator Brings First AML and Cybersecurity Enforcement Action against Licensed Crypto Trading Entity

Proskauer - Blockchain and the Law on

In what is the New York Department of Financial Services’ (NYDFS) first enforcement action against a NYDFS-licensed “virtual currency business,” on August 1, 2022, the agency announced $30 million settlement with...more

Robinson+Cole Data Privacy + Security Insider

New York DFS Fines Robinhood $30M for “Significant” Cybersecurity Violations

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The New York Department of Financial Services (DFS) announced its first ever penalty against a cryptocurrency platform this week, with a whopping $30 million fine assessed against Robinhood Crypto, LLC (RHC) for what it...more

Goodwin

Stress Test Scenarios Released for 2022

Goodwin on

In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Alston & Bird

Treasury FinCEN Releases Financial Trend Analysis of Ransomware Trends in 2021

Alston & Bird on

On October 15, 2021 the Financial Crimes Enforcement Network (FinCen) of the Treasury Department issued a financial trend analysis on ransomware relating to Bank Secrecy Act (BSA) reporting filed in the first half of this...more

Skadden, Arps, Slate, Meagher & Flom LLP

FINRA Issues Guidance Encouraging Firms To Prepare for Forthcoming Anti-Money Laundering Rules

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On October 8, 2021, the Financial Industry Regulatory Authority (FINRA) issued a Regulatory Notice urging its member firms (i.e., broker-dealers) to consider how they will incorporate the U.S. Treasury Department’s...more

Goodwin

SCOTUS Vacates Class Certification In Suit Against Goldman Sachs And Clarifies Appropriate Scope Of Price Impact Evidence

Goodwin on

SCOTUS Vacates Class Certification In Suit Against Goldman Sachs And Clarifies Appropriate Scope Of Price Impact Evidence; Stockholders Strike $110 Million Settlement In Suit Alleging Breaches Of Fiduciary Duties By Former...more

Foodman CPAs & Advisors

FinCEN to host second ‘exchange’ on preventing ransomware

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The United States Treasury Department’s Financial Crimes Enforcement Network (FinCEN) will hold a second FinCEN Exchange in August to discuss ways to combat increasingly sophisticated cyber and ransomware attacks. The FinCEN...more

WilmerHale

FinCEN Publishes No-Action Letter Analysis and AML/CFT National Priorities

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The Financial Crimes Enforcement Network (“FinCEN”) has continued a spate of regulatory activity related to financial crimes compliance matters in the first year of the Biden Administration, recapped in its recent report...more

Foley & Lardner LLP

New FinCEN Anti-Money Laundering Priorities

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Financial Crimes Enforcement Network (FinCEN) remains committed to combating money laundering, in all forms, in connection with the banking and financial systems. To this end, on June 30, 2021, FinCEN issued new...more

Eversheds Sutherland (US) LLP

FinCEN on fire: Rapid release of AML Act updates

Eversheds Sutherland (US) LLP on

On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) provided an update on implementation of the Anti-Money Laundering Act of 2020 (AML Act) and issued the first government-wide priorities for anti-money...more

BCLP

Sharper Lines Mean Tighter Nets: How the FinCEN’s Latest Priorities are Another Step to Increased Enforcement

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In the latest sign that the federal enforcement apparatus is slowly but surely training its sights on white-collar professionals and businesses, particularly financial services, the Financial Crimes Enforcement Network...more

King & Spalding

FinCEN Issues Anti-Money Laundering and Countering the Financing of Terrorism Priorities

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FinCEN announces eight areas of focus and advises preparation for issuance of new regulations - On June 30, 2021, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the first...more

Levenfeld Pearlstein, LLC

Cybersecurity And Anti-Corruption As National Security Concerns

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On June 3, 2021, President Joe Biden issued a new directive instructing federal agencies to ramp up their anti-corruption initiatives as a matter of U.S. foreign policy and national security. The National Security Study...more

Bracewell LLP

Biden Administration Prioritizes Increased and Broadened Anti-Corruption Enforcement

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On June 3, 2021, the White House issued a memorandum announcing anti-corruption as a core national security interest. The memorandum explains that, “[c]orruption threatens United States national security, economic equity,...more

Perkins Coie

Fintech Week in Review - April 2021

Perkins Coie on

Federal Financial Regulators Seek Information on the Use of AI by Financial Institutions - On March 29, 2021, five federal financial regulatory agencies (the Federal Reserve, CFPB, FDIC, OCC, and NCUA) announced a request...more

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