News & Analysis as of

Criminal Investigations FinCEN

Orrick, Herrington & Sutcliffe LLP

What Companies Need To Know About New Whistleblower Reward Programs

The U.S. Department of Justice (DOJ) has announced plans to offer financial incentives to whistleblowers who report allegations of wrongdoing. It’s an effort to fill gaps left open by existing whistleblower and bounty...more

A&O Shearman

Announcement of new DOJ Whistleblower Policy

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On March 7, 2024, Deputy Attorney General Lisa Monaco announced a new 90-day pilot program at the Department of Justice (DOJ) to incentivize whistleblowers. The program is inspired by and generally follows similar programs...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Financial Institution Officers

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The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Akin Gump Strauss Hauer & Feld LLP

7 Enforcement Predictions For US Export Controls, Sanctions

Within the trade bar there is cautiousness, curiosity and skepticism at the numerous pronouncements signaling greater enforcement of export controls and sanctions by the Bureau of Industry and Security, the Office of Foreign...more

Ballard Spahr LLP

FinCEN Issues Alert on COVID-19 Employee Retention Tax Credit Fraud

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On November 22, 2023, the Financial Crimes Enforcement Network (“FinCEN”), in close coordination with the Internal Revenue Service (“IRS”) Criminal Investigation (“CI”), issued an alert (“Alert”) regarding the COVID-19...more

Venable LLP

Honesty is Good for Your Bottom Line: Commerce, Treasury, and DOJ Tout the Benefits of Voluntary Self Disclosure in Tri-Seal...

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Voluntary self-disclosure is a valuable remediation measure for companies who identify their own potential violations of U.S. sanctions, export controls, and other national security laws....more

Skadden, Arps, Slate, Meagher & Flom LLP

Cryptoasset Seizures and Forfeitures: US and UK Enforcement Overview

Regulatory scrutiny of the use and management of cryptocurrency and other digital assets such as utility tokens and non-fungible tokens (NFTs) (collectively, cryptoassets) is rapidly growing on both sides of the Atlantic....more

Ballard Spahr LLP

GAO Report: DOJ Cannot Provide Meaningful Feedback on SAR Use

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How effective is the current framework for filing Suspicious Activity Reports, or SARs? The AML Act mandates that federal law enforcement agencies provide statistics to assist Congress, regulators, and financial institutions...more

King & Spalding

Managing Global Risks in Light of the Pandora Papers Leak

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On October 3, the International Consortium of Investigative Journalists began reporting on millions of confidential documents relating to the financial activities of heads of state, international business leaders, and other...more

Ballard Spahr LLP

FinCEN issues assessment on possible “no-action” letters for industry

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As required by the Anti-Money Laundering Act (“AML Act”), the Financial Crimes Enforcement Network (“FinCEN”) issued on June 30, 2021 its 14-page assessment regarding the feasibility of FinCEN issuing so-called “no-action”...more

Freeman Law

The FBAR (Report of Foreign Bank and Financial Accounts): Everything You Need to Know

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What is the Report of Foreign Bank and Financial Accounts (FBAR)? Congress enacted the statutory basis for the requirement to report foreign bank and financial accounts in 1970 as part of the “Currency and Foreign...more

Ballard Spahr LLP

Federal Banking Agencies Issue Joint Statement On Enforcement of BSA/AML Requirements; FinCEN Follows With Its Own

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Regulators Provide Greater Transparency into BSA/AML Enforcement Process - On August 13, 2020 the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the...more

Ballard Spahr LLP

Key Developments in the Prosecutions for Leaks by Government Personnel of SARs Related to Michael Cohen, Paul Manafort, Richard...

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Note to Government Personnel: Don’t Disclose SARs - This week, major developments unfolded in the cases against two former federal government employees for their respective roles in disclosing Suspicious Activity Reports...more

Ballard Spahr LLP

U.S. Treasury and DOJ Targets “Evil Corp”

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Organization Excels at Niche Branding but Stumbles in Avoiding Enforcement - The first paragraph of the press release sums it up: Today the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) took action...more

Holland & Knight LLP

Virtual Currency: The Taxman is Coming

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Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more

Ballard Spahr LLP

FinCEN Director Blanco Addresses AML Compliance and Casinos

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FinCEN Director Kenneth A. Blanco delivered prepared remarks on August 13 at the 12th Annual Las Vegas Anti-Money Laundering Conference.  We previously have blogged repeatedly on the anti-money laundering (“AML”) and Bank...more

Ballard Spahr LLP

FinCEN Dispenses Law Enforcement Awards Based on BSA Reporting

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Director Blanco Stresses Importance of BSA Filings to Criminal Investigations and Prosecutions - As we have blogged, Kenneth Blanco, the Director of Financial Crimes Enforcement Network (“FinCEN”), has publically and...more

Dechert LLP

US Blockchain Enforcement and Litigation Update

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Cross-Border Investigations Update - November 2017

This issue of Skadden’s semiannual Cross-Border Investigations Update takes a close look at recent cases, regulatory activity and other key developments, including new U.K. reporting obligations for sanctions violations,...more

Ballard Spahr LLP

Manafort Indictment Alleges High-End International Money Laundering and Tax Fraud Involving Offshore Accounts

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As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more

Ballard Spahr LLP

High-Profile Spanish Money Laundering Investigation of Chinese Bank Raises Questions About Future of Similar U.S. Enforcement

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As widely reported, the Spanish police raided last year the Madrid offices of the Chinese state-run Industrial and Commercial Bank of China (“ICBC”), the world’s biggest bank by assets. In the nearly 18 months following that...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Action Demonstrates the Agency’s Ability to Use Anti-Money Laundering Laws Against Non-U.S. Entities

On Wednesday, July 27, 2017, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $110 million fine levied against BTC-e, a digital currency exchange, for BTC-e’s alleged refusal to abide by...more

Ballard Spahr LLP

FinCEN Takes First Action Against Foreign-Located MSB—“The Virtual Currency Exchange of Choice for Criminals”—For Willfully...

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On July 26, FinCEN, in coordination with the U.S. Attorney’s Office for the Northern District of California (“NDCA USAO”), assessed a $110,003,314 civil money penalty against BTC-e a/k/a Canton Business Corporation (“BTC-e”)...more

The Volkov Law Group

Beneficial Ownership Due Diligence Requirements

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The new FinCEN regulations requiring financial institutions to secure beneficial ownership information is fast approaching – May 2018. The US has been way behind in this regulatory area. As a result, money-laundering activity...more

Holland & Knight LLP

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

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In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

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