News & Analysis as of

Civil Monetary Penalty Enforcement Actions Anti-Money Laundering

Davis Wright Tremaine LLP

Broker-Dealer Disciplinary Actions: Takeaways From 2024 (So Far)

The U.S. Securities and Exchange Commission (SEC), the Financial Industry Regulatory Authority (FINRA), and the Exchanges were active across a host of regulatory issues impacting fintech companies and broker-dealers during...more

Kohn, Kohn & Colapinto LLP

FinCEN Head Praises New AML Whistleblower Program

The passage of the Anti-Money Laundering (AML) Whistleblower Improvement Act in December 2022 was heralded by whistleblower advocates as a major development which would transform the ability of the U.S. to crack-down on money...more

Sheppard Mullin Richter & Hampton LLP

Binance’s Paper Compliance Program Crumples Under OFAC Scrutiny in Largest OFAC Settlement in History

On November 21, 2023, the U.S. Office of Foreign Assets Control (OFAC) announced its largest settlement in history with the virtual currency exchange Binance. This almost-billion dollar settlement is a part of a larger...more

The Volkov Law Group

OFAC Settlement with DaVinci Payments Is Wake-Up Call for Prepaid Access Industry

The Volkov Law Group on

Rewards programs have become ubiquitous in recent years. These so-called loyalty management programs exist to nudge customers or employees in a particular direction; a company’s workers might be inclined to exercise more...more

WilmerHale

The Gambling Commission reaffirms its status as one of the UK’s most active AML enforcement authorities.

WilmerHale on

On 28 March 2023, the UK Gambling Commission (the Commission) announced that three gambling businesses owned by William Hill Group would pay a total financial penalty of £19.2 million for social responsibility and anti-money...more

Orrick, Herrington & Sutcliffe LLP

FDIC issues January enforcement actions

On February 24, the FDIC released a list of administrative enforcement actions taken against banks and individuals in January. The FDIC made public 11 orders, including “four combined orders of prohibition and orders to pay...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $200 Million in Penalties for BSA-AML Violations

On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent...more

Sheppard Mullin Richter & Hampton LLP

OCC and FinCEN Issue $9 Million in Penalties for BSA-AML Violations

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) and the Financial Crimes Enforcement Network (“FinCEN”) issued civil monetary penalties against a Texas community bank for violations of the Bank...more

WilmerHale

CFTC 2020 Enforcement and Regulatory Developments and a Look Forward

WilmerHale on

2020 saw continuity in CFTC leadership, programs, and direction from 2019. Overall, the Commission enjoyed an unusually heavy rulemaking calendar and continued the direction of its enforcement program from 2019. On the...more

The Volkov Law Group

Citigroup Fined $400 Million by Banking Regulators for Risk and Compliance Control Deficiencies

The Volkov Law Group on

Banking regulators, the Office of Comptroller of the Currency and the Federal Reserve, recently collected a $400 million civil penalty against Citigroup for long-standing deficiencies in its enterprise risk management,...more

Foodman CPAs & Advisors

If you Exchange Virtual Currency, you are a Money Transmitter and must comply with the Bank Secrecy Act (BSA)

FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more

Jones Day

Financial Crimes Enforcement Network Consolidates Guidance on Virtual Currencies

Jones Day on

The Situation: The Financial Crimes Enforcement Network ("FinCEN") released interpretive guidance concerning the application of the Bank Secrecy Act ("BSA") and the anti-money laundering ("AML") regulations to certain...more

Dechert LLP

FCA Enforcement Risk: The Year Ahead

Dechert LLP on

Firms will need to ensure their systems and controls to prevent financial crime and money laundering are working effectively: this is just part of the message contained in the FCA’s Business Plan for 2019/20. The Business...more

Orrick - On the Chain

FinCEN Shows a Little Bite to Go with Its Bark

Orrick - On the Chain on

Last week, the Financial Crimes Enforcement Network (FinCEN) backed up its strong public statements about enforcing the anti-money laundering (AML) laws with respect to cryptocurrency by bringing an enforcement action against...more

Burr & Forman

FinCEN Announces Civil Monetary Penalty for Virtual Currency Exchanger

Burr & Forman on

On April 18, 2019, the Financial Crimes Enforcement Network (“FinCEN”) announced its first enforcement action against a peer-to-peer virtual currency exchanger....more

Dechert LLP

US Blockchain Enforcement and Litigation Update

Dechert LLP on

Over the past two years, prices for cryptocurrencies and other digital assets have experienced extreme gains and declines, while billions of dollars have been raised through Initial Coin Offerings (“ICOs”). In this dynamic...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Ballard Spahr LLP

The BSA Civil Penalty Regime: Reckless Conduct Can Produce “Willful” Penalties

Ballard Spahr LLP on

Conduct Performed Without Knowledge Still Can Lead to the Most Serious Penalties - Under the Bank Secrecy Act (“BSA”), the most onerous civil penalties will be applied for “willful” violations....more

Ballard Spahr LLP

FinCEN Extends $3 Million Carrot to Card Club and Casino: Reduce Assessed Civil Penalty by Completing Compliance Undertakings

Ballard Spahr LLP on

FinCEN announced on May 3, 2018 that Artichoke Joe’s, a card club and casino located in San Bruno, California and founded in 1916, has entered into a revised civil money penalty assessment regarding alleged deficiencies under...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Russian

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - Chinese

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - February 2018

ANTICORRUPTION DEVELOPMENTS – U.S. Agencies Decline to Prosecute Teradata for Alleged FCPA Violations – On February 26, 2018, Teradata Corporation, an Ohio-based enterprise software database management company,...more

Sullivan & Worcester

Object Lesson on How Not to Respond to Consent and Enforcement Actions

Sullivan & Worcester on

Last week, the DFS announced an enforcement action and charges against the NY Branch of Habib Bank, a Pakistani bank that had been doing business in NY for almost 40 years....more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

Foley & Lardner LLP

White Collar Enforcement and the New Trump Administration: Your Top Ten Questions Answered

Foley & Lardner LLP on

Enforcement activity under the Obama administration often made headlines for the eye-popping level of fines, with the Foreign Corrupt Practices Act (FCPA), Anti-Money Laundering (AML) regulations, and economic sanctions...more

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