CFIUS recently published a summary of their 2015 CFIUS Annual Report to Congress.  CFIUS is charged with reviewing foreign investments and advising the President on appropriate actions that may be necessary to suspend or prohibit foreign acquisitions, mergers, or takeovers which threaten to impair the national security of the United States. The Annual Report reflects a trend over the last two years that CFIUS is closely scrutinizing more foreign investment transactions and increasingly taking action.…

Investment advisers subject to SEC registration would be affected by proposed regulations from the Financial Crimes Enforcement Network.  The regulations, proposed in August 2015, would require such investment advisers to create anti-money laundering programs as well as to undertake reporting and recordkeeping responsibilities under the Bank Secrecy Act, including filing suspicious activity reports. For more information on this topic, please click here.…

On 24 November 2013, the P5+1 countries (comprising the United States, Russia, China, the United Kingdom, France and Germany) together with Iran, agreed the Joint Plan of Action (JPOA), which relaxed some of the sanctions imposed against Iran by the EU and U.S. The JPOA was intended to provide interim sanctions relief, while the parties worked towards a more comprehensive and long-term solution. On 14 July 2015, the Joint Comprehensive Plan of Action (JCPOA) was agreed.…

In our alert of 8 July, we reported that the P5+1 and Iran had announced the extension of the Joint Plan of Action Relief Period (the JPOA Relief Period) to today, 10 July 2015. Negotiations with Iran continue. To allow more time for the parties involved to reach a long-term solution, the JPOA Relief Period has been further extended to Monday, 13 July 2015. As with the previous extension, the suspension and relaxation of…

Introduction Stephanie Booker, Associate Director for Enforcement, Financial Crimes Enforcement Network (“FinCEN”) recently gave a speech at the Nevada Bar Association’s Bank Secrecy Act Conference in Las Vegas. Involved in the conference were the State Bar of Nevada’s Gaming Law Section, the American Gaming Association, and the University of Nevada-Las Vegas’ International Gaming Institute. FinCEN is one of the Treasury Department’s primary agencies to oversee and implement policies to prevent and detect money laundering, and…

On June 15, multiple federal agencies issued a $4.5 million penalty against a local bank that admitted to failing to maintain an effective anti-money laundering program. The coordinated enforcement action by multiple agencies and substantial monetary penalty illustrates the significant risks for anti-money laundering compliance for local financial institutions. The coordinated action was announced by the U.S. Attorney’s Office for the Southern District of West Virginia, the Federal Deposit Insurance Corporation (FDIC), and the U.S.…

On June 3, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a $75 million penalty against a Northern Mariana Islands casino for Bank Secrecy Act violations – the largest-ever FinCEN penalty assessed against a casino. FinCEN’s announcement follows an investigation of the casino, Hong Kong Entertainment (Overseas) Investments, Ltd., d/b/a Tinian Dynasty Hotel & Casino (Tinian Dynasty), in which the casino was found to lack an anti-money laundering program altogether. FinCEN has regulatory authority…