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Financial Transactions Enforcement Actions

The Volkov Law Group

TD Banks’ Pervasive and Systemic Criminal Misconduct (Part II of IV)

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“By making its services convenient for criminals, TD Bank became one,” Attorney General Merrick B. Garland. TD Bank joins the list of dysfunctional companies — add them to Wells Fargo, Wirecard, Volkswagen, General Motors,...more

Foley Hoag LLP

Highlights from CFIUS’ 2023 Annual Report to Congress

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On July 23, 2024, the Committee on Foreign Investment in the United States (CFIUS) published its Annual Report to Congress for the Calendar Year 2023. The report provides key statistics on the CFIUS process and the...more

The Volkov Law Group

State Street’s $7.45MM OFAC Penalty Highlights Importance of Sanctions in M&A Due Diligence

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The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) has released a $7.45 million penalty against State Street Bank and Trust Company and its non-bank, fintech subsidiary Charles River Systems for...more

Womble Bond Dickinson

Enhancing Trade-Based Money Laundering Detection: Retrieval-Augmented Generation and Semantic Search Technologies

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This article explores the application of retrieval-augmented generation combined with semantic search technologies in the detection of trade-based money laundering (TBML). Retrieval-augmented generation combined with semantic...more

Polsinelli

Blockchain+ Bi-Weekly - April 2024 #2

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The focus in Web3 law the past few weeks has been on jurisdictional issues when litigating matters involving borderless digital asset transactions. This is expected to be an ongoing issue, as courts work through these...more

Pillsbury Winthrop Shaw Pittman LLP

Non-U.S. Companies on Alert: U.S. Government Issues Tri-Seal Compliance Note on Global Enforcement

New Tri-Seal Compliance Note highlights sanctions and export control compliance expectations for non-U.S. persons. Three agencies overseeing U.S. trade law compliance provided an overview of where U.S. sanctions and export...more

The Volkov Law Group

Lessons Learned from Binance’s Criminal Settlement (III of III)

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Binance’s $4.3 billion fine is one of the largest penalties the DOJ has ever obtained from a corporate defendant.  Furthermore, its founder and CEO Changpeng Zhao (“CZ”) was also personally subject to a fine, amounting to...more

The Volkov Law Group

Binance Intentionally Avoided Compliance with U.S. Laws Under CEO Changpeng Zhao (II of III)

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Binance’s settlement with the DOJ represents one of the largest criminal corporate enforcement actions ever.  A review of the facts reveals that the penalty is likely warranted, as the misconduct was driven from the very...more

The Volkov Law Group

DOJ Reaches Groundbreaking Criminal Settlement with Cryptocurrency Exchange Binance and CEO Changpeng Zhao (Part I of III)

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On November 21, 2023, The U.S. Department of Justice (“DOJ”) announced settlement agreements with Binance Holdings Limited (“Binance”), the world’s largest cryptocurrency exchange, and Changpeng Zhao (affectionally known as...more

Thomas Fox - Compliance Evangelist

The Binance Enforcement Action

Binance, the world’s largest cryptocurrency trading platform, has recently been hit with a staggering $4.3 billion fine for intentionally violating anti-money laundering laws and other financial regulations. This landmark...more

Gray Reed

Release the Kraken Tax Transaction Information

Gray Reed on

On June 30, 2023 the District Court in the Northern District of California granted a petition to enforce the cryptocurrency exchange Kraken to release customer information.  Specifically, Kraken was ordered to produce the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Acts Against Fintech Operator of Mobile App for Illegal International Money Transfers

On October 17, the CFPB took action against a nonbank fintech company for allegedly deceiving consumers about the speed and cost of remittance transfers through its mobile app. The Bureau also alleges that the company...more

Polsinelli

Blockchain+ Bi-Weekly - October 2023 #2

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The Blockchain Bi-Weekly presented by the Polsinelli Blockchain+ team is a rundown of some of the key stories in the Web3, blockchain and crypto ecosystems curated by our attorneys navigating the intersections of code, smart...more

Ballard Spahr LLP

Steel Company President with Ties to Russian Oligarch Pleads Guilty to Money Laundering Conspiracy Involving Alleged Sanctions...

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Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial transactions committed with...more

Oberheiden P.C.

OFAC Compliance: Developing and Implementing an Effective Sanctions Compliance Program

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Financial institutions and companies that are subject to oversight from the Office of Foreign Assets Control (OFAC) need to prioritize compliance. OFAC has become increasingly active in recent years, and it is devoting...more

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

A&O Shearman

SEC charges Impact Theory for unregistered offering of NFTs

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On August 28, 2023, the Securities and Exchange Commission (the “SEC”) charged Impact Theory, LLC (“Impact Theory”), a media and entertainment company headquartered in Los Angeles, with conducting an unregistered securities...more

Troutman Pepper

Securities Industry Arbitrations and Litigation Update: FINRA Reaffirms Its Commitment to Enforcement Actions In Connection with...

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Mindful of the impending retirement of many millions of investors in the “baby boomer” generation, which hold a substantial amount of the world’s wealth, the Financial Industry Regulatory Authority (FINRA) continues to...more

Sullivan & Worcester

“What to do if things start to go wrong in a Trade, Export or Project Finance Transaction”

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Jacqueline Cook, Of Counsel, sums up the key messages from Sullivan’s May webinar. Geoffrey Wynne considered what financiers could do if things start to go wrong in a trade, export or project finance transaction and...more

Orrick, Herrington & Sutcliffe LLP

OFAC reaches $508 million settlement with British tobacco company on North Korean transactions

On April 25, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) announced a $508 million settlement with one of the world’s largest tobacco companies to resolve potential civil liabilities stemming from...more

Akin Gump Strauss Hauer & Feld LLP

Federal Agency Settlements with Wells Fargo Illustrate Sanctions Risks Involving IT Systems

Key Points - On March 30, 2023, OFAC announced a settlement agreement with Wells Fargo for 124 apparent violations of three different sanctions programs (Iran, Syria and Sudan), all related to a legacy Wachovia Bank...more

The Volkov Law Group

Wells Fargo Fumbles Sanctions Compliance Demonstrating An Absence of Culture of Compliance (Part II of II)

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Not that I am a glutton for punishment, but I always find enforcement actions to supply a number of valuable lessons learned. There are always instructive nuggets of information, opportunities missed, and root causes that...more

The Volkov Law Group

Wells Fargo Pays OFAC $30 Million to Settle Sanctions Violations (Part I of II)

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In our lifetime (however long or short), there is no way any company will ever match Wells Fargo for its record of misconduct, criminal and civil enforcement, and regulatory fines and penalties.  No one, no way....more

Cadwalader, Wickersham & Taft LLP

Special Alert: SVB/Signature Receiverships: Key Impacts of SVB/Signature Receiverships on Fund Finance Transactions

It has been a chaotic 72 hours, with changing facts, breaking news and unexpected developments. The market turmoil has kept us scrambling to figure out how best to get deals closed, to keep money moving and to meet our...more

BakerHostetler

PoS Principles Published; Crypto Market Analysis and POC Announced; Court Interprets NFTs Under Howey; SEC, CFTC and DOJ Continue...

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Proof of Stake Alliance Publishes Analysis, Advocates for Industry Standards - This week the Proof of Stake Alliance (POSA), a nonprofit industry alliance focused on proof of stake (PoS) ecosystems, announced their newly...more

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