The Financial Action Task Force (“FATF”) has re-rated the U.S. as “largely compliant” with FATF’s Recommendation 24, which pertains to transparency related to beneficial ownership of legal persons. Specifically, FATF...more
Today we are very pleased to welcome, once again, guest blogger Dr. Kateryna Boguslavska of the Basel Institute on Governance (“Basel Institute”), who will discuss the Basel Institute’s release of the 12th annual Public...more
The Financial Action Task Force (“FATF”) recently released its Report on the State of Effectiveness and Compliance with the FATF Standards (“Report”). The Report contains the results of its 4th Round of Mutual Evaluations...more
The U.S. Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the U.S. Federal Reserve System (FRB) proposed new rules that would expand the applicability of recordkeeping and travel rule requirements,...more
Beginning on October 21, 2020, the Financial Action Task Force (“FATF”) held its three-day Plenary meeting virtually. It was the first Plenary of Germany’s two-year Presidency. As part of the Plenary outcomes, the FATF...more
The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more
Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more
Law Enforcement Has Been Using GTO Data - First of Two Posts on Evolving Issues Regarding Real Estate and Money Laundering - The U.S. Government Accountability Office (“GAO”) has issued a report on the status and...more
LIBOR transition and PRA resolution-related rules: PRA statement - The UK Prudential Regulation Authority (PRA) has published a statement outlining the PRA's view on the implications of LIBOR transition for contracts in...more
En mayo del 2020, el FATF (GAFI) publicó nuevas amenazas y vulnerabilidades de lavado de dinero y financiamiento del terrorismo derivadas de la crisis COVID-19. El documento destaca cómo el fraude, el cibercrimen, la mala...more
On May, 2020, the FATF published new money laundering and terrorist financing threats and vulnerabilities arising from the COVID-19 crisis. The document highlights how fraud, cybercrime, misdirection of government funding...more
The Financial Action Task Force (“FATF”) just released an important report entitled Money Laundering and the Illegal Wildlife Trade (the “Report”). The lengthy and detailed Report makes clear that the IWT is pernicious...more
Earlier this month, senior officials of the global money laundering and terrorist financing watchdog—the Financial Action Task Force (FATF)—issued a paper identifying challenges, good practices, and policy responses to new...more
With respect to customers, Financial Institutions are required to have processes in place for identifying Politically Exposed Persons – known as “PEPs”. ...more
FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more
On May 18, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advisory “to alert financial institutions to rising medical scams related to the COVID-19 pandemic. This [A]dvisory contains red flags, descriptions of...more
On May 4, the Financial Action Task Force (“FATF”) issued a paper entitled “Covid-19-Related Money Laundering and Terrorist Financing – Risk and Policy Responses (“Paper”). ...more
Beneficial ownership is a topic which presents significant challenges to compliance officers charged with untangling a web of ownership interests that span numerous international jurisdictions and ownership structures. ...more
Second Post in a Two-Post Series on Recent FATF Activity - As we just blogged, the Financial Action Task Force (“FATF”) issued a statement from its President on COVID-19 and measures to combat illicit financing during the...more
First Post in a Two-Post Series on Recent FATF Activity - Members presumably working from home, the Financial Action Task Force (“FATF”) was active last week, first issuing its 3rd Enhanced Follow-up Report & Technical...more
The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/CFT threats. ...more
In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more
The G20 has urged countries to adopt the Financial Action Task Force (FATF) standards on virtual assets and virtual asset service providers, which were adopted in June last year. ...more
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
On January 29, 2020, the U.S. Government Accountability Office (GAO) publicly released the results of a study which the GAO conducted on trade-based money laundering, or TBML, entitled “Countering Illicit Finance and Trade:...more