All Things Investigations: Episode 30 - The Convergence of ABC, AML and Export Controls with Mike Huneke and Jan Dunin-Wasowicz
BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]
In this first-of-its kind enforcement action, the FCC has proposed forfeitures not only against a party for allegedly instigating a deepfake, robocall campaign, but also against the voice provider for alleged STIR/SHAKEN...more
The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more
Crypto assets are some of the most rapidly evolving and increasingly adopted assets in the world. Decentralized Finance (DeFi) is emerging as a blockchain-based alternative to traditional banking and financial services and...more
On May 13, the Federal Communications Commission’s (FCC or Commission) Enforcement Bureau (Bureau) classified for the first time a group of entities and individuals – dubbed “Royal Tiger” – as a Consumer Communications...more
Last week, the United States Attorney’s Office for the Southern District of New York unsealed an indictment against global cryptocurrency exchange KuCoin and two of its founders, Chun Gan and Ke Tang, for allegedly conspiring...more
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
ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more
Could you provide an insight into recent trends shaping financial crime in your country of focus? How great a risk does money laundering in particular now pose to companies? One would likely never imagine compliance as...more
On December 13, 2023, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”) announced an enforcement action against CoinList Markets LLC (“CoinList”) for violations of the Ukraine-/Russia-Related...more
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
Hong Kong regulators recently brought criminal enforcement actions against virtual asset trading platform JPEX and individuals associated with the platform. This case has become the first opportunity for local authorities to...more
The UK Financial Conduct Authority (FCA) has assessed the systems and controls relating to sanctions compliance for over 90 firms across a range of sectors and summarised its findings of good and poor practice. Acknowledging...more
ACI’s highly anticipated Proficiency Series provides true immersion in the EAR with the objective of becoming proficient in four weeks. Join virtually from September 12 – October 5, 2023! Advance your career and...more
On June 5, 2023, the SEC filed an extensive civil complaint against Binance Holdings Limited, its assorted affiliates and its beneficial owner and CEO, Changpeng Zhao, alleging multiple violations of the Securities Act of...more
The cryptocurrency industry has a target on its back – and perhaps justifiably so. The SEC, CFTC and OFAC have been bringing a number of regulatory enforcement actions, including against Bittrex, Inc. ($24,280,829.20 in...more
On January 4, 2023, the New York State Department of Financial Services (“DFS”) announced that Coinbase, Inc., a major U.S. cryptocurrency exchange, will pay a $50 million penalty and invest an additional $50 million in its...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important and interesting SEC enforcement developments from the past month, with links to primary...more
Privy Council rules against extension of the Quincecare duty - Does a bank owe a duty of care to a person who is the beneficial owner of funds held in the account of a customer of the bank and who has been defrauded by...more
For years, the cryptocurrency wallets of U.S. taxpayers have existed in a reporting gray zone. However, as it becomes clear that crypto asset transactions are not slowing down, the Internal Revenue Service (IRS) has signaled...more
Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more
Cryptocurrency, and its most-noted asset Bitcoin, has been breaking into the mainstream press. While most lawyers have heard terms like “blockchain” and probably even know a few people who have been deeply interested in the...more
Compliance Solutions Across Industries - Are you looking to: - Create a stronger compliance program for your organization? - Explore key takeaways from recent international and domestic enforcement actions? -...more
On Friday March 12, Bloomberg News reported that the Commodity Futures Trading Commission (“CFTC”) has opened an inquiry into Binance Holdings Ltd. (“Binance”) to investigate allegations that the exchange allowed US citizens...more
The CFTC recently joined the host of other federal and state regulators who enforce anti-money laundering laws, by bringing three cases finding violations of CFTC Regulation 42.2. Regulation 42.2 requires futures commission...more
DOJ’s Cyber Digital Task Force’s report, “Cryptocurrency: An Enforcement Framework,” provides a comprehensive on the growing partnerships between DOJ and other offices within the executive branch....more