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Steel Company President with Ties to Russian Oligarch Pleads Guilty to Money...
Earlier this month, John Can Unsalan, the president of a steel-making company with ties to Russian oligarchs, pled guilty to one count of conspiracy to commit money laundering, based on financial...
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SEC Exam Priorities Target AML
Priorities Echo Prior Alerts and Enforcement Actions The SEC’s Division of Examinations (the “Division”) released on October 16 a report on its “Examination Priorities” (the “Report”) for fiscal year...
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FinCEN Renews and Expands GTO
FinCEN announced on October 20 that, once again, it is extending the Geographic Targeting Order, or GTO, which requires U.S. title insurance companies to identify the natural persons behind so-called...
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FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing...
On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency...
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CFPB Issues Proposal to Supervise Nonbank Providers of Digital Wallets and...
The CFPB has issued a proposed rule to supervise nonbank companies that qualify as larger participants in a market for “general-use digital consumer payment applications.” Comments on the proposal...
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FinCEN and BIS Issue Joint Notice on SAR Filings for Evasion of U.S. Export...
The Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) recently issued Joint Notice FIN-2023-NTC2, “Announnc[ing] New...
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SDNY Court Finds Broad Fed Powers Over Master Accounts in Puerto Rican Bank...
The United States District Court for the Southern District of New York (the “Court”) has issued a detailed and complicated Order in the case Banco San Juan Internacional, Inc. v. Fed. Reserve Bank of...
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FinCEN Expands CTA FAQs
On November 16, the Financial Crimes Enforcement Network (“FinCEN”) issued – again –expanded FAQs pertaining to beneficial ownership information (“BOI”) reportable under the Corporate Transparency Act...
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Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for...
A Huge Monetary Penalty for Sprawling Allegations – But Will Zhao Receive a Prison Sentence? As the world now knows, Binance Holdings Limited, doing business as Binance.com (“Binance” or the...
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FinCEN Issues Alert on COVID-19 Employee Retention Tax Credit Fraud
On November 22, 2023, the Financial Crimes Enforcement Network (“FinCEN”), in close coordination with the Internal Revenue Service (“IRS”) Criminal Investigation (“CI”), issued an alert (“Alert”)...
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FinCEN Extends CTA Reporting Deadline for New Companies from 30 to 90 Days
The Financial Crimes Enforcement Network (“FinCEN”) has extended the deadline for reporting beneficial ownership information (“BOI”) under the Corporate Transparency Act (“CTA”) for reporting...
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Hamas, Terrorist Financing, and Cryptocurrency
The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular,...
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OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs
In its Fall 2023 Semiannual Risk Perspective, published on December 7, the Office of the Comptroller of the Currency (“OCC”) reported on key issues facing the federal banking system. In evaluating...
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FinCEN Issues Final CTA BOI Access Rules, Heralded by YouTube Video
This morning, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial...
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Money Laundering Watch: 2023 Year in Review
Farewell to 2023, and welcome 2024. As we do every year, let’s look back. We highlight 10 of our most-read blog posts from 2023, which address many of the key issues we’ve examined during the past...
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SDNY Grants Ex Parte Applicants the Ability to Subpoena Deutsche Bank...
On December 14, 2023, the United States District Court for the Southern District of New York (the “Court”) granted an unusual ex parte application to serve third-party discovery subpoenas on...
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Final CTA Access Rule Answers Some Questions, and Leaves Open Others
The beneficial ownership information (“BOI”) registry under the Corporate Transparency Act (“CTA”) is now up and running at the Financial Crimes Enforcement Network (“FinCEN”). This post will follow...
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FinCEN Analysis Reveals $212 Billion in Identity-Related Suspicious Activity
The Financial Crimes Enforcement Network (“FinCEN”) recently released a Financial Trend Analysis (“FTA”) focusing on identity-related suspicious activity. The FTA was issued pursuant to section 6206...
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The Basel AML Index: Forfeiture, Non-Profits, Crypto, and More. A Guest Blog.
Today we are very pleased to welcome, once again, guest blogger Dr. Kateryna Boguslavska of the Basel Institute on Governance (“Basel Institute”), who will discuss the Basel Institute’s release of the...
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Criminal Case Round-Up: Recent Prosecutions Involving Casinos
First of Three Posts in a Related Series on Recent AML and Money Laundering Prosecutions The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering...
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