News & Analysis as of

Banking Sector Anti-Money Laundering Policies and Procedures

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on

Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Oberheiden P.C.

5 Anti-Money Laundering Compliance and Defense Tips

Oberheiden P.C. on

1. AML Laws - Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Sullivan & Worcester

FFIEC Examination Procedures for the Beneficial Ownership Rule

Sullivan & Worcester on

The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more

Pillsbury Winthrop Shaw Pittman LLP

Beyond BSA Compliance: Human Trafficking Corporate Liability for Small Banks and MSBs

Smaller banks and money services businesses should expand their AML compliance to mitigate human trafficking corporate liability. Aside from the Bank Secrecy Act, federal law creates corporate liability for financial...more

Bracewell LLP

SEC's Office of Compliance Inspections and Examinations 2018 Examination Priorities

Bracewell LLP on

On February 7, 2018, the Office of Compliance Inspections and Examinations (“OCIE”) of the U.S. Securities and Exchange Commission (“SEC”) published its 2018 examination priorities. OCIE’s examination priorities are...more

Bass, Berry & Sims PLC

Anti-Money Laundering Update: FinCEN Makes Small Texas Bank Pay Big Fine for Violating Bank Secrecy Act

Bass, Berry & Sims PLC on

This Post at a Glance: - FinCEN imposes $2 million penalty against community bank - Bank failed to conduct appropriate due diligence related to Mexican customer - Small banks, other financial institutions need to...more

K2 Integrity

Five Areas of Focus for the New CDD Rule

K2 Integrity on

While regulators haven’t yet spelled how the new customer due diligence (CDD) requirements for financial institutions will be implemented, banks, credit unions, securities firms, money services businesses, and casinos should...more

Manatt, Phelps & Phillips, LLP

FinCEN Seeks to Add Investment Advisers to BSA/AML Regulation

Why it matters - More than 12 years after initially proposing to extend the Bank Secrecy Act's anti-money laundering compliance programs and recordkeeping and reporting requirements to investment advisers, the Financial...more

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