Eighth Blog Post in an Extended Series on Legislative Changes to the BSA/AML Regulatory Regime As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) contains major changes to the Bank Secrecy Act (“BSA”), coupled with other changes relating to money laundering, anti-money laundering (“AML”), counter-terrorism financing (“CTF”) and protecting the U.S. financial system against illicit foreign actors.   In this post, we review several provisions of the AMLA section entitled “Modernizing the Anti-Money…

Seventh Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime On April 5, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued an advance notice of proposed rulemaking (“ANPRM”) to solicit public comment on questions pertaining to the implementation of the Corporate Transparency Act (“CTA”), passed as part of the Anti-Money Laundering Act of 2020 (“AMLA”).  The CTA requires certain legal entities to report their beneficial owners at the time of their creation…

Much has occurred in the last two months regarding the relationship between financial institutions and Marijuana-Related Businesses, or MRBs.  In this post, we discuss three major developments, all of which share a complex connection.  First, the National Credit Union Administration (“NCUA”) recently pursued its first enforcement action against a credit union for Anti-Money Laundering (“AML”) compliance failures when servicing MRBs.  Second, two cannabis industry executives were convicted of bank fraud for allegedly tricking banks and…