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Criminal Liability Financial Institutions

ArentFox Schiff

Supreme Court Rules in NRA v. Vullo: Landmark Decision Upholds First Amendment Rights

ArentFox Schiff on

On May 30, the US Supreme Court, in National Rifle Ass’n of Am. v. Vullo, 602 US __ (2024), unanimously held that the National Rifle Association (NRA) plausibly alleged in a complaint that it filed in federal court that...more

BCLP

Personal Matters - How will the risks to firms from individuals’ behaviour increase in 2024?

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Financial regulators in the UK have been interested for some years in the question of how personal behaviour can affect the risk profile of a financial institution. A recent SEC case suggests that US regulators may now be...more

Oberheiden P.C.

National Security in the Age of Blockchain

Oberheiden P.C. on

Blockchain presents unprecedented challenges around national security. This is true not only for the federal government, but also for businesses in the private sector. From cross-border transactions involving cryptocurrency...more

WilmerHale

United States V. Danske Bank: New Theory of Liability for Violation of US AML Standards

WilmerHale on

This Article discusses the recent plea agreement between the United States and Danske Bank. It argues that the Department of Justice has advanced a new and evolving theory of liability for foreign banks that access the U.S....more

Lowenstein Sandler LLP

SVB FALLOUT: How VC-backed Startups May Extend Payroll & Avoid Furloughs

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In light of the FDIC takeover of Silicon Valley Bank (SVB), many of our startup, growth company, and fund clients have asked about how to manage their obligations to pay their team members during a period when the company’s...more

Dechert LLP

Economic Crime (Transparency and Enforcement) Act 2022 (the "Act") – Answering Your Questions

Dechert LLP on

This note summarizes those provisions of the Act applicable to England and Wales that deal with the new register of overseas entities ("ROE") that has been established at Companies House in the UK. It seeks to identify and,...more

Cozen O'Connor

AGs Urge Creation of Safe Harbor for Financial Institutions Serving Cannabis Businesses

Cozen O'Connor on

Writing as co-chairs of the National Association of Attorneys General Federalism Committee, Ohio AG Dave Yost and Colorado AG Philip Weiser wrote a letter to Senate Majority Leader Chuck Schumer and Senate Minority Leader...more

Moore & Van Allen PLLC

Human Trafficking Awareness – What Financial Institutions Need to Know

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Anti-Money Laundering and Know Your Customer departments at financial institutions are on the front lines of human trafficking. Not only does enhanced transaction monitoring help law enforcement identify trafficking...more

Burns & Levinson LLP

Part 4: Hot Smoking Topics in Operations

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The growth and legitimacy of the cannabis industry is at an all-time high with nearly two-thirds of the country in support of the federal legalization of cannabis. With such legitimacy and potential for further growth, it’s...more

A&O Shearman

Sanctions Risk: Drafting Contracts to Avoid ‘Double Jeopardy’

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In the recent case of Lamesa Investments Ltd v Cynergy Bank Ltd [2019] EWHC 1877 (Comm), the High Court upheld the bank’s attempt to avoid a common banking dilemma: the ‘double jeopardy’ of being contractually liable to make...more

Faegre Drinker Biddle & Reath LLP

DOJ and CFTC Bring Actions Against Precious Metals Traders

Recently, the Department of Justice indicted three precious metals traders in the Northern District of Illinois, charging each them with violating the Racketeer Influenced and Corrupt Organization Act (“RICO”), committing...more

Dechert LLP

The Calamity of the Weaponized Narrative

Dechert LLP on

Tim Sloan resigned as the CEO of Wells Fargo a few months ago. I had briefly worked with Tim and much admired him so, on a personal level, this was sad. Now, Mr. Sloan’s resignation might have been a compelling and obvious...more

White & Case LLP

SAR Reform: Law Commission publishes report

White & Case LLP on

The Law Commission has published its much anticipated report on reform of the UK's anti-money laundering and terrorism financing regime, and in particular of the system of suspicious activity reports ("SARs"). The proposed...more

Burns & Levinson LLP

Update: SAFE Banking Act of 2019

Burns & Levinson LLP on

As we discussed in a post back in February, one of the biggest hurdles facing the legal cannabis industry today remains the lack of access to banking services. Despite the legalization of cannabis on the state level, banks...more

BCLP

A Delicate Balance

BCLP on

How should we approach competing sanctions risks? Among the numerous regulatory compliance risks faced by financial institutions, economic and trade sanctions risks commonly receive a great deal of attention....more

Carlton Fields

Is Cannabis Banking "SAFE"? Marijuana and Its Secure and Fair Enforcement

Carlton Fields on

On March 28, 2019, the House Financial Services Committee voted overwhelmingly (45-15) to advance H.R. 1595, known as the Secure and Fair Enforcement (SAFE) Banking Act of 2019. The bill seeks to protect financial...more

White & Case LLP

Cross-Border Cannabis Investment: Managing Money Laundering Risk

White & Case LLP on

Canada legalised recreational cannabis in October 2018 and it may be that other countries follow suit. UK and US investors, and those who facilitate investments in legal recreational cannabis businesses overseas, need to be...more

Bradley Arant Boult Cummings LLP

O Canada! What Canada’s Nationwide Legalization of Cannabis Means for American Financial Institutions

Today marks a significant shift in cannabis policy, both domestically and internationally, as Canada becomes the first industrialized nation in the world, and only the second nation overall, to legalize cannabis. This follows...more

Jones Day

Russian President Putin Signs New Law in Retaliation for U.S. Sanctions

Jones Day on

Retaliatory Sanctions - On June 4, 2018, Russian President Putin signed the Federal Law "On Measures to Counter Unfriendly Actions of the United States of America and/or Other Foreign States" after it was overwhelmingly...more

Pillsbury Winthrop Shaw Pittman LLP

South Carolina Begins Licensing Money Transmission

South Carolina Anti-Money Laundering Act becomes effective May 25, 2018. Applications must be filed by June 29, 2018. Implementing regulations become effective May 25, 2018. ...more

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