Popular, Banking Sector, BSA/AML

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on 9/19/2024

Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

Navigating the Labyrinth: Artificial Intelligence in the Battle Against Trade-Based Money Laundering

Womble Bond Dickinson on 2/7/2024

In the rapidly evolving financial landscape, governments worldwide are intensifying their focus on compliance in Know Your Customer (KYC) and Anti-Money Laundering (AML) efforts for financial institutions. Trade-Based Money...more

Federal Court Holds Financial Institution Liable for Business Email Compromise Loss

Davis Wright Tremaine LLP on 2/27/2023

While ransomware attacks usually grab the headlines, business email compromise (BEC) attacks continue to cause massive financial losses for businesses. The FBI’s Internet Crime Complaint Center (IC3), reported BEC losses in...more

NY Department of Financial Services Outlines How Blockchain Analytics Should Be Used for Compliance

Skadden, Arps, Slate, Meagher & Flom LLP on 5/18/2022

On April 28, 2022, the New York State Department of Financial Services (DFS) issued guidance on the use of blockchain analytics for virtual currency businesses licensed under 23 NYCRR part 200 (also known as a BitLicense) or...more

Real Estate and Money Laundering: FinCEN Issues Advanced Notice of Regulations for the Real Estate Industry

Ballard Spahr LLP on 12/14/2021

On December 6, FinCEN announced that it was issuing an Advanced Notice of Proposed Rulemaking (“AMPRM”) to solicit public comment on potential requirements under the Bank Secrecy Act (“BSA”) for certain persons involved in...more

Supreme Court Decision Empowers President Biden to Replace Director of FHFA

Goodwin on 6/25/2021

In This Issue. In a move that gives him the opportunity to put his stamp on housing policy and the potential overhaul of Fannie Mae and Freddie Mac, President Biden replaced the Director of the Federal Housing Finance Agency...more

Financial Services Report - Summer 2021

Morrison & Foerster LLP on 6/9/2021

As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more

5 Anti-Money Laundering Compliance and Defense Tips

Oberheiden P.C. on 5/18/2021

1. AML Laws - Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more

Massive BSA/AML Reform Legislation Released by U.S. House and Senate Committees for Passage — But Still Subject to Potential...

Ballard Spahr LLP on 12/7/2020

On December 3, the U.S. House and Senate Armed Services Committees reached an agreement on the National Defense Authorization Act (“NDAA”), an annual defense spending bill. Within this huge bill (well over 4,500 pages) are...more

FinCEN Issues Advisory on Cyber-Enabled Crime Fueled by COVID-19

Ballard Spahr LLP on 7/31/2020

The Financial Crimes Enforcement Network (“FinCEN”) just issued yet another Advisory regarding fraud threats faced by financial institutions, as exacerbated by the COVID-19 pandemic. This Advisory pertains to “Cybercrime and...more

Cyber-Enabled Financial Crime and Money Laundering

Ballard Spahr LLP on 7/29/2020

Today we are very pleased to welcome guest blogger Moyara Ruehsen, PhD, CAMS, CFCS, who is an Associate Professor and Director of the Financial Crime Management Program at the Middlebury Institute of International Studies in...more

Data Privacy + Cybersecurity Insider - February 2019 #2

Robinson & Cole LLP on 2/18/2019

To illustrate just how creative phishing campaigns have become, on January 30, 2019, it was reported by multiple credit unions that Bank Secrecy Act officers at credit unions around the country received emails that appeared...more

To Catch a Terrorist – Innovation, AI, and Public/Private Partnerships in the World of BSA/AML

Bradley Arant Boult Cummings LLP on 12/4/2018

On the heels of FinCen and Federal Banking Agencies releasing a joint statement “Encouraging Innovative Industry Approaches to AML Compliance,” Under Secretary for Terrorism and Financial Intelligence Sigal Mandelker...more

AML Compliance Lessons Learned from US Bancorp and Rabobank Enforcement Actions

The Volkov Law Group on 4/19/2018

Global banks have been the focus of enforcement actions, focusing on AML and sanctions violations. With the new beneficial ownership regulations effective May 11, 2018, we are about to see a significant transformation in AML...more

AML/BSA Focus by U.S. Senate Committee Testimony – From Beneficial Ownership to Cryptocurrency

Ballard Spahr LLP on 2/8/2018

This week, the U.S. Senate Committee on the Judiciary and the U.S. Senate Committee on Banking, Housing and Urban Affairs held hearings focused in part on Anti-Money Laundering (“AML”) and the Bank Secrecy Act (“BSA”)....more

OCC Report Identifies Cybersecurity and AML as Key Risks for Federal Banking System

Ballard Spahr LLP on 1/22/2018

Last week, the OCC released its semiannual risk report highlighting credit, operational, and compliance risks to the federal banking system. The report focuses on issues that pose threats to those financial institutions...more

The Courts Speak: Bank Liability for Alleged AML Failures Impacting Third Parties, and Hauling into U.S. Court Foreign Defendants...

Ballard Spahr LLP on 11/20/2017

We discuss two recent federal court opinions addressing two issues of increasing frequency and importance: (i) the potential civil liability of financial institutions to non-customers and other third-parties for alleged...more

Money Laundering Watchdog Criticizes Lax AML Enforcement and “Creative Compliance” in Wake of Panama Papers

Ballard Spahr LLP on 10/27/2017

PANA Issues Recommendations to European Parliament: Tougher Enforcement, Greater Transparency, Improved Information Sharing and Prohibitions Against Outsourcing of Customer Due Diligence....more

FinCEN Issues New Geographic Targeting Order for Shell Companies Purchasing High-End Residential Real Estate

Cadwalader, Wickersham & Taft LLP on 8/29/2017

In its latest effort to combat money laundering within the real estate sector, the Financial Crimes Enforcement Network (“FinCEN”) has issued a new Geographic Targeting Order (“GTO”) broadening its scrutiny of shell companies...more

High-Profile Spanish Money Laundering Investigation of Chinese Bank Raises Questions About Future of Similar U.S. Enforcement

Ballard Spahr LLP on 8/7/2017

As widely reported, the Spanish police raided last year the Madrid offices of the Chinese state-run Industrial and Commercial Bank of China (“ICBC”), the world’s biggest bank by assets. In the nearly 18 months following that...more

FinCEN Takes First Action Against Foreign-Located MSB—“The Virtual Currency Exchange of Choice for Criminals”—For Willfully...

Ballard Spahr LLP on 7/31/2017

On July 26, FinCEN, in coordination with the U.S. Attorney’s Office for the Northern District of California (“NDCA USAO”), assessed a $110,003,314 civil money penalty against BTC-e a/k/a Canton Business Corporation (“BTC-e”)...more

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