Recent Developments in Anti-Money Laundering - The Consumer Finance Podcast
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The Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Treasury Department, has issued a proposed rule (the “Proposal”) that would subject certain investment advisers to anti-money laundering (“AML”)...more
The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more
The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more
In 2022, anti-money laundering ("AML") and sanctions controls were at the center of regulatory and enforcement activities in the United States and abroad. Globally, governments have continued to recognize the impact of AML...more
Enforcement Trends, Crypto, Regulatory Developments — and More - I am very pleased to co-chair again the Practicing Law Institute’s 2023 Anti-Money Laundering Conference on May 16, 2023, starting at 9 a.m. in New York City...more
In parallel with the Office of Foreign Assets Control (“OFAC”), the Financial Crimes Enforcement Network (“FinCEN”) settled with Bittrex, Inc. (“Bittrex”), a cryptocurrency exchange that allows users to trader virtual assets,...more
It would be the height of folly to claim that a single theme dominates the AML Act of 2020 (Act). The new law, enacted on January 1 of this year, is an extraordinarily wide-ranging and long overdue reform of the Bank Secrecy...more
On 23 October, the Treasury Committee launched a further inquiry to review what progress has been made in combatting economic crime. While the inquiry is focused on the effectiveness of the existing anti-money laundering...more
Financial institutions with anti-money laundering responsibilities under the Bank Secrecy Act (BSA) take note: there’s a new sheriff in town. The Commodity Futures Trading Commission recently finished its fiscal year with...more
In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more
FinCEN Director Ken Blanco addressed this year’s Consensus Blockchain Conference on May 13, 2020. In a set of prepared remarks, Blanco recognized the unprecedented challenges that the COVID-19 pandemic has created for...more
On February 25, 2020, the Tenth Circuit Court of Appeals upheld the dismissal of shareholders’ securities-fraud class action against the Western Union Company (“Western Union”) and several of its current and former executive...more
Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more
Note to Government Personnel: Don’t Disclose SARs - This week, major developments unfolded in the cases against two former federal government employees for their respective roles in disclosing Suspicious Activity Reports...more
AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more
Virtual currency transactions are now a prime focus of Internal Revenue Service (IRS) scrutiny. The IRS has numerous information-gathering tools to enforce its taxing power, including summons, artificial intelligence, data...more
Earlier this month, the leaders of the U.S. Commodity Futures Trading Commission, the Financial Crimes Enforcement Network, and the U.S. Securities and Exchange Commission released a joint statement reminding individuals...more
A bipartisan group of Senators, with the support of the American Bankers Association, recently introduced bill S.2563, known as the ILLICIT Cash Act. The acronym “ILLICIT” stands for “Improving Laundering Laws and Increasing...more
On August 21, 2019, FinCEN issued an advisory (the “Advisory”) alerting financial institutions to various financial schemes and mechanisms employed by fentanyl and synthetic opioid traffickers to facilitate the illegal...more
FinCEN defines a Money Service Business (MSB) as any person DOING BUSINESS, whether or not on a regular basis or as an organized business concern, in one or more of the following capacities...more
On June 12, 2019, Kenneth A. Blanco, Director of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), provided remarks at the NYU Law Program on Corporate Compliance and Enforcement that underscored the agency’s...more
The Suspicious Activity Report (SAR) was created by five federal financial agencies and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN)....more
The Financial Crimes Enforcement Network (FinCEN) is the U.S. Treasury Department bureau charged with monitoring financial transactions in order to combat domestic and international money laundering, terrorist financing and...more
Marijuana is estimated to be a $10 billion industry and rapidly growing. Almost all of it is conducted in cash. Although legal in thirty three states plus Washington, D.C., Puerto Rico and Guam, marijuana remains illegal at...more
UBS Group agreed to pay a combined $15 million penalty to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”)and the SEC for regulatory deficiencies in its anti-money laundering compliance program. ...more