Farewell to 2022, and welcome 2023. As we do every year, let’s look back.
We highlight 12 of our most-read blog posts from 2022, which address many of the key issues we’ve examined during the past year: the Corporate Transparency Act (“CTA”) and beneficial ownership reporting; sanctions — particularly sanctions involving Russia; cryptocurrency and digital assets; BSA/AML compliance and its tension with de-risking; and implementation of the AML Act:
- FinCEN Issues Final Rule on Beneficial Ownership Reporting Requirements
- FinCEN Final Rule for Beneficial Ownership Reporting: The “Substantial Control” Prong
- Privacy, Cybersecurity and Access to Beneficial Ownership Information: FinCEN Issues Notice of Proposed Regulations Under the Corporate Transparency Act
- Russian Agent’s Beverly Hills Condominiums Subject to Forfeiture Based on Alleged Violations of Bank Fraud, Money Laundering, and U.S. Sanctions Statutes
- Russian Sanctions Redux: FinCEN Issues Guidance on Suspicious Transactions and Evasion Using High-Value Assets
- OFAC and FinCEN Settle with Bittrex in Parallel Virtual Currency Enforcements
- OFAC Sanctions Virtual Currency “Mixer” Tornado Cash and Faces Crypto Backlash
- NYDFS Releases Virtual Currency Guidance for Banking Organizations
- U.S. Treasury Releases 2022 Strategy for Combatting Terrorist and Other Illicit Financing
- A Paradox: “De-Risking” Can Increase AML/CFT Risks By Driving People into the “Shadow Banking System”
- FinCEN and Federal Functional Regulators Issue Coded Warnings Against De-Risking
- Implementation of the AMLA and the CTA by Financial Institutions: A Podcast
We now move on to 2023. This year also will be an important and interesting year for BSA/AML and money laundering issues: criminal and civil enforcement cases continue to unfold across industries, crypto is undergoing intense scrutiny, and FinCEN must issue final regulations under the CTA and AML Act — and, possibly, as to the real estate industry. We look forward to keeping you informed throughout 2023 on these and other developments.
We also want to thank our many readers around the world who continue to make this blog such a success. The feedback we receive from financial industry professionals, compliance officers, in-house and external lawyers, BSA/AML consultants, government personnel, journalists, and others interested in this field is invaluable, and we hope you will continue to share your perspectives with us. We pride ourselves on providing in-depth discussions of the important developments in this ever-evolving area.