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Beneficial Owner White Collar Crimes

American Conference Institute (ACI)

Sanctions Compliance Measures to Mitigate Russia Trade Sanctions Evasion Tactics

The various and elusive tactics used by Russia to evade global sanctions and export controls have grown increasingly sophisticated over the last several months, putting the onus on multinational entities to become equally...more

Best Best & Krieger LLP

What You Need to Know About the U.S. Corporate Transparency Act

Practical Issues for Entity Management - The Corporate Transparency Act (CTA) is new legislation passed by Congress as part of the Anti-Money Laundering Act of 2020. This legislation sets forth uniform beneficial ownership...more

The Volkov Law Group

FinCEN Issues Final Rule for Beneficial Ownership Reporting

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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

Dechert LLP

Register of Overseas Entities Comes into Force – are you ready?

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Earlier this year Dechert reported on the new Register of Overseas Entities ("ROE"), introduced in March as Part 1 of the Economic Crime (Transparency and Enforcement) Bill (the "Bill"). The Bill was enacted on 15 March 2022,...more

Dechert LLP

Foreign Land Owners Come into the Light…UK Government introduces new “Register of Overseas Entities”

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On 1 March the Home Office introduced the Economic Crime (Transparency and Enforcement) Bill (the "Bill"). The most significant change, introduced in Part 1 of the Bill, is the creation of a new, public "Register of Overseas...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

The Volkov Law Group

Biden Administration Announces New Anti-Corruption Strategy (Part I of III)

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The Biden Administration announced a new, comprehensive anti-corruption program, the United States Strategy on Countering Corruption. The new anti-corruption policy is the follow on to the earlier announcement elevating the...more

A&O Shearman

Pandora Papers Fallout: Proposed US Legislation Targets “Enablers” of Money Laundering

A&O Shearman on

The release of the Pandora Papers, a leak of approximately 12 million documents, exposed how foreign leaders and private actors use tax havens to conceal their wealth, with the United States a destination of choice. For...more

The Volkov Law Group

The Coming AML Enforcement Storm

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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

K2 Integrity

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

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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

Cohen & Gresser LLP

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

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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

The Volkov Law Group

Beneficial Ownership: Identification and Mitigation (Part IV of IV)

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We are finally reaching the end of the road on the beneficial ownership path.  In this last posting on the issue (for now), let’s start with a third-party population (third parties, vendors, suppliers) which have been...more

The Volkov Law Group

Practical Risk-Based Ranking Strategies to Beneficial Ownership Issues (Part III of IV)

The Volkov Law Group on

At the outset, if you have a headache after reading my first two posts on the beneficial ownership issue, I apologize.  The issues twist and turn depending on whether the situation involves OFAC sanctions or corruption risks,...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

Ballard Spahr LLP

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

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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

Ballard Spahr LLP

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

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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

Orrick, Herrington & Sutcliffe LLP

The implementation of the Fifth Anti Money Laundering Directive in German Law – Tighten the tight?

In the course of the “Panama Paper” scandal, Directive (EU) 2015/849 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing – known as 4. Anti-Money Laundering...more

Ballard Spahr LLP

The EU’s Efforts to Combat Money Laundering, the Financing of Terrorism and Corruption Seem to Overlook a Very American Approach:...

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The European Union (“EU”) recently has grappled with a series of massive money laundering scandals and strategized about how to more effectively combat international money laundering and corruption. Generally, the EU has...more

The Volkov Law Group

Five Common Weaknesses in OFAC Sanctions Compliance Programs

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As companies elevate their “game” in sanctions compliance, it is important that compliance officers critically examine the strengths and weaknesses of their compliance programs.  Many companies already have a screening...more

Ballard Spahr LLP

Corporate Transparency Act of 2019 Broadens Beneficial Ownership Reporting

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In early March, the House Financial Services Committee released three proposed bills to codify many of the suggested reforms discussed during ongoing conversation among financial agencies, law enforcement, financial...more

Ballard Spahr LLP

First U.S. Indictment Relating to Panama Papers Charges Lawyer, Asset Manager, Accountant and Client

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DOJ Targets Professional Enablers of Alleged Tax and Laundering Schemes - On December 4, the Office of the U.S. Attorney for the Southern District of New York unsealed an elaborate indictment charging three professionals —...more

Ballard Spahr LLP

“Panama Papers” Law Firm Announces Its Closure Due to Fallout from Massive Data Breach

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The beleaguered law firm at the center of the international Panama Papers scandal – Mossack Fonseca – has announced that it is closing its doors. It offered no apologies....more

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