News & Analysis as of

BSA/AML White Collar Crimes Compliance

Thomas Fox - Compliance Evangelist

Using RegTech To Enhance the Fight Against Financial Crime

Have you heard these common myths about anti-money laundering technology solutions? Myth 1: Anti-money laundering technology solutions are only necessary for financial institutions. Myth 2: Anti-money laundering technology...more

The Volkov Law Group

DOJ Outlines Aggressive White Collar Enforcement Measures and New Compliance Expectations (Part I of II)

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The Justice Department continues to push on white collar corporate enforcement, and the intersection of national security sanctions and export controls with corporate criminal enforcement.  Last week, Lisa Monaco, DOJ’s...more

BakerHostetler

$3.6 Billion Reasons to Up Cryptocurrency Compliance: FBI Cracking Down on Crypto Criminals

BakerHostetler on

Key Takeaways - ..Banks and cryptocurrency exchanges need to update their BSA programs to account for the unique aspects of cryptocurrencies, detect and report related suspicious activity, and minimize the risk of...more

The Volkov Law Group

The United States Strategy on Countering Corruption: Digging into the Anti-Corruption Initiatives (Part III of III)

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The new United States Strategy on Countering Corruption includes several important statements of interest to legal and compliance professionals.  ...more

The Volkov Law Group

FINRA Reminds Broker-Dealers on Importance of Compliance with New AML Rules

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The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements.  There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will...more

The Volkov Law Group

The Transformative Role of “National AML Priorities” for Compliance in the AML Act of 2020

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It would be the height of folly to claim that a single theme dominates the AML Act of 2020 (Act). The new law, enacted on January 1 of this year, is an extraordinarily wide-ranging and long overdue reform of the Bank Secrecy...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

The Volkov Law Group

Biden Administration Ramping Up Anti-Corruption Effort

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The Biden Administration is taking over the reins of government with vigor and focus. The Department of Justice, the Treasury Department, the State Department and the Commerce Department are expected to coordinate closely in...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

Mitratech Holdings, Inc

Reduced Cost and Enhanced Impact: Embedding Compliance in BAU

Compliance management has moved from being a nice to have, to an absolute need to have. For many organizations, it is part of business-as-usual (BAU). The scale and scope of compliance frameworks across the world have grown,...more

The Volkov Law Group

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

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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

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

Thomas Fox - Compliance Evangelist

A Cheater is a Cheater and a Stinker is a Stinker

Something is very rotten in both Denmark around its banks regarding AML and the Houston Astros and their leadership. Before and during the World Series, Astros management engaged in either some of the most boneheaded conduct...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

Thomas Fox - Compliance Evangelist

The OFAC Compliance Framework: Element 4 & 5 – Testing and Auditing & Training

After a short visit to Val Lewton’s Cat People, I return to conclude this multipart series on the Framework for OFAC Compliance Commitments (Framework). Every compliance professional of any stripe needs to read, understand...more

Thomas Fox - Compliance Evangelist

What is Innovation in Compliance and Why is it so Hard? Part IV

Over the past few blog posts, I have been exploring a recent article in Harvard Business Review (HBR)  by Gary P. Pisano, entitled “The Hard Truth About Innovative Cultures”....more

The Volkov Law Group

Financial Institutions and the Glaring Absence of an Ethical Culture

The Volkov Law Group on

Federal prosecutors and regulators have been active in tackling US banks. In the last few weeks, the Federal Reserve took the extraordinary step of blocking Wells Fargo’s ability to grow its business until it improves its...more

The Volkov Law Group

Anti-Money Laundering Risks for Global Companies (Part I of III)

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Non-financial institution companies operating in the global marketplace face ever-increasing risks of money laundering. Sophisticated criminal organizations have developed their own mechanisms and strategies to skirt money...more

The Volkov Law Group

AML Enforcement and Compliance Trends

The Volkov Law Group on

Law enforcement focus on anti-money laundering appears to be increasing. While the last ten years has seen a marked increase in AML regulatory obligations, the new administration is likely to return to some of the more...more

Thomas Fox - Compliance Evangelist

How the Yellow Submarine Informs Due Diligence Lessons From 1MDB

Enrichment is the theme for today’s post as it is personal and illegal enrichment which seems to be the continuing message from the 1MDB scandal involving the disgraced Malaysian sovereign wealth fund. In an article in the...more

Thomas Fox - Compliance Evangelist

Compliance Isn’t Going Away (and neither should you) – Part I

Yesterday I presented my views on why I believe that Foreign Corrupt Practices Act (FCPA) enforcement will continue under the new administration. Today, I want to begin a multi-part series (sorry I don’t know how long it will...more

The Volkov Law Group

Customer Due Diligence in the Post-Panama Papers Era

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Sometimes it takes a scandal to advance a policy or law enforcement cause. The Panama Papers scandal has given new life to financial regulators around the world who seek to impose customer due diligence requirements on banks...more

Carlton Fields

Closing Gaps? FinCEN Proposes Anti-Money Laundering Rule for Investment Advisers

Carlton Fields on

After more than a decade of delay, the Financial Crimes Enforcement Network (FinCEN) of the Department of Treasury issued a notice of proposed rulemaking that would require registered investment advisers to establish...more

Carlton Fields

Anti-Money Laundering Trends: Facts, Findings, and Lessons Learned

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Increased anti-money laundering (AML) regulation enforcement by federal and state agencies in recent months should have financial institutions across the country reviewing and strengthening their in-house AML policies and...more

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