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 year: criminal money laundering enforcement; compliance risks with third-party fintech relationships; the scope of authority of bank regulators; sanctions evasion — particularly sanctions involving Russia; cryptocurrency and digital assets; AML enforcement by the SEC; and BSA/AML compliance and its tension with de-risking.
- Binance Settles Criminal and Civil AML and Sanctions Enforcement Actions for Billions – While its Founder, Owner and Former CEO Zhao Pleads Guilty to Single AML Crime
- FinCEN Analysis Reveals Patterns and Trends in Suspected Evasion of Russia-Related Export Controls
- SEC Issues Alert Outlining Deficiencies in Broker-Dealers’ AML Compliance
- Hamas, Terrorist Financing, and Cryptocurrency
- SDNY Sentences Danske Bank in Massive AML Scandal
- All Roads Lead to Roman: Alleged Tornado Cash Co-Founders Roman Storm Arrested and Roman Semenov Sanctioned, Days After Treasury Defeats Lawsuit Challenging OFAC
- Will Ciminelli’s Impact on Wire Fraud Cases Ripple Out to Bank Fraud?
- Department of Treasury Issues Strategy on De-Risking
- SDNY Court Finds Broad Fed Powers Over Master Accounts in Puerto Rican Bank Case Involving AML Concerns
- OCC Risk Perspective Report Focuses on Third-Party Relationships with Fintechs
We move on to 2024. It will be another critical year, as the Corporate Transparency Act (“CTA”) is now in effect — with regulations pertaining to the alignment of the CTA and the Customer Due Diligence Rule still to come. FinCEN also is expected to issue proposed regulations for the real estate industry, AML whistleblowing, and, potentially, investment advisors. Criminal and regulatory enforcement relating to digital assets and fintech and third-party relationships will continue. We look forward to keeping you informed throughout 2024 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.
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