There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more
On the one hand, the year ended where it began. The legislation on stabelecoins and market structure that would provide a regulatory framework for digital assets has still not been enacted into law. And Securities and...more
On September 15, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced its first “Gap Rule” enforcement action in a Consent Order with Bancrédito International Bank and Trust...more
The market for digital assets has exploded in recent years. Digital and virtual currency activities provide great opportunities financially and technologically. However, such currencies can be utilized for illicit activity...more
TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more
The New York State Department of Financial Services (NYDFS) has come out strongly against an Office of the Comptroller of the Currency (OCC) proposal to grant national bank charters to financial technology (fintech)...more
Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more
With the Panama Papers scandal and government promises of continued aggressive AML enforcement, financial institutions face a variety of risks that require increased vigilance and mitigation strategies....more