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]
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
On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more
The U.S. Department of Commerce's ("Commerce") Bureau of Industry and Security ("BIS") has issued a proposed rule (the "Proposed Rule") that would impose significant diligence, reporting, and recordkeeping requirements on...more
On January 29, 2024, the Department of Commerce, Bureau of Industry and Security (BIS) released a proposed rule (Proposed Rule) that would require U.S. cloud services providers (a.k.a. Infrastructure as a Service, or IaaS,...more
On January 29, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a proposed rule (the Proposed Rule) that would impose significant know-your-customer (KYC), monitoring and reporting obligations...more
Many entities across the United States are about to have increased reporting requirements starting January 1, 2024. After a long anticipated-wait, FinCEN, the Financial Crimes Enforcement Network, issued a final rule on the...more
Welcome to the November edition of Akin Intelligence. Looking back, October 2023 may be remembered as the month when the U.S. government tried to assume the mantle of global leadership on responsible artificial intelligence...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
Although the Corporate Transparency Act (CTA”) was adopted in 2021, implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) established regulations. The deadline,...more
企業透明性法（以下「法」）は2021年に採択されたが、財務省の金融犯罪取締ネットワーク（以下「FinCEN」）が規制を設ける間、施行が遅れていました。しかし、その遵守期限は間近に迫っています。2024年1月1日以降に設立される報告対象会社は、設立後30日以内に報告書を提出する必要があります。2023年末時点ですでに存在する報告対象会社は、2024年末までに最初の報告を行う必要があります。...more
Although the Corporate Transparency Act (the “Act”) was adopted in 2021, implementation has been delayed while the Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) established regulations. The...more
The rising incidence of financial crime continues to haunt financial institutions globally. As per a recent industry report, more SARs (suspicious activity reports) were filed by ~80% of the firms in 2021. COVID-19 pandemic...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
Executive Summary - The U.S. Congress recently passed the Corporate Transparency Act (“CTA”) as part of the 2021 National Defense Authorization Act. The CTA requires certain corporations, limited liability companies and...more
Human trafficking is a global crisis that has an impact on lives around the globe. Over time, there have been many initiatives taken by governments and nonprofits to identify and help victims while promoting enhanced...more
The Corporate Transparency Act (CTA), part of the 2021 National Defense Authorization Act enacted into law on January 1, 2021, will impose new beneficial ownership reporting requirements on many companies. The stated purposes...more
Effective as of January 1, 2021, Congress enacted - over President Trump's veto - the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (the "NDAA"). As with any U.S. defense bill, the NDAA...more
In the government’s continuing effort to combat money-laundering, Congress recently passed the Corporate Transparency Act (CTA) to require private companies to disclose their “beneficial owners” to the U.S. Department of the...more
FinCEN Cites Low Risk of Money Laundering and High Regulatory Burden of Rule - On September 7, 2018, the Financial Crimes Enforcement Network (“FinCEN”) issued permanent exceptive relief (“Relief”) to the Beneficial...more
Interagency Statement on Accounting and Reporting Implications of the New Tax Law - On January 18, 2018, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal...more