Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more
El 02/23/24, el Grupo de Acción Financiera Internacional (GAFI o “FATF”), una entidad intergubernamental independiente que desarrolla políticas para la protección de nuestro sistema financiero global contra el lavado de...more
On 2/23/24, the Financial Action Task Force (FATF), an independent inter-governmental entity that develops policies for protection of our global financial system from money laundering, terrorist financing and financing of...more
On February 24, the Financial Action Task Force (FATF), the international standard-setting body on illicit finance, suspended the Russian Federation’s membership, saying the country’s “actions unacceptably run counter to the...more
Domestic terrorism is not a new threat in America, but in recent years we have seen a significant and horrific increase in violent attacks and activities carried out by individuals and groups motivated by a range of radical...more
On March 9, 2022, President Joseph Biden issued Executive Order 14067, which charged the Department of Justice (in consultation with the Departments of State, Treasury, and Homeland Security) to submit a report on how to...more
In this Issue. The Financial Crimes Enforcement Network (FinCEN) published an alert warning financial institutions of possible efforts to evade U.S.-imposed sanctions on Russia and Belarus; the U.S. Department of the Treasury...more
Reports Address Crypto M&A and Metaverse, New Crypto Products Launch - A Big Four accounting firm recently released its “2021 Global Cryptocurrency Mergers and Acquisition and Fundraising Report.” Key takeaways from the...more
Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more
This coming Saturday is the 20th anniversary of the attacks upon America on September 11, 2001. Like most Americans, this was the seminal event in the history of our country. I have been thinking a lot about that date and the...more
The Regulation Process for FinCEN’s New Beneficial Ownership Reporting Requirement Launches - The Financial Crimes Enforcement Network (FinCEN) issued an Advanced Notice of Proposed Rulemaking (ANPRM) on Thursday to solicit...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
Treasury Secretary Steven Mnuchin remarked before a hearing of the Senate Finance Committee three weeks ago that “significant new requirements at FinCEN” for cryptocurrencies would be introduced quickly, in response to...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
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
• The U.S. Securities and Exchange Commission (SEC) staff made official statements regarding when a token may or may no longer be a security • The SEC continued to bring actions related to cryptocurrency offerings against...more
The Fourth European Union Anti-Money Laundering Directive (Fourth AML Directive), approved by the European Parliament on May 20, 2015, went into effect on June 25, 2015, repealing the 2005 Third AML Directive. Given the...more
RMBS Suit Against WMC Mortgage LLC Dismissed as Time-Barred - On July 10, 2015, Judge Alvin Hellerstein of the Southern District of New York granted defendant WMC Mortgage LLC's motion for judgment on the pleadings in an...more
On June 12, 2015, Treasury Department issued its National Money Laundering Risk Assessment (NMLRA) and National Terrorist Financing Risk Assessment (NTFRA). This is the Department’s first NMLRA release in a decade and its...more
For the first time in a decade, the Treasury Department has released its own anti–money laundering (AML) and terrorist financing Risk Assessments, which may both set a strategic framework for future AML regulatory...more