Money Laundering Watch

Insights and news on the world of financial corruption

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By: Ballard Spahr LLP

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Anthony C. Kaye
David L. Axelrod
Dennis K. Burke
William J. Burton
Juliana B. Carter
Andrew N. D'Aversa
Brad Gershel
Terence M. Grugan
Gretchen L. Gurstelle
Peter D. Hardy
John D. Socknat
Jeremy C. Sairsingh
Brian N. Kearney
Kevin D. Leitão
Alexander Kommatas
Evan W. Krick
Joanna H. Kunz
Edward J. McAndrew
Beth Moskow-Schnoll
Brian D. Pedrow
Marjorie J. Peerce
Kristen Poetzel
Richard J. Andreano, Jr.
Priya Roy
Stefanie Jackman
R. Stephen Stigall
Mary K. Treanor
Stacey L. Valerio
Jessica C. Watt
Alicia M. Went

Latest from Money Laundering Watch

Federal legislators continue to struggle over the growing disconnect between increasing State legalization of the cannabis industry, and the continued illegality of cannabis under federal law. This struggle represents an increasingly pressing question for financial institutions, given the burgeoning market involving cannabis-related products – including third parties who provide services and equipment to growers and distributors – and its need for safe, traditional banking services. The latest chapter in this struggle was a hearing, entitled…
As we have blogged (here and here), the United States – despite its self-perception as a global financial cop and “good guy” – is often regarded by the world as a haven for money laundering and tax evasion. The U.S. just took another black eye in the arena of global perception: the European Commission (“EC”) has placed the U.S. Virgin Islands, Puerto Rico, Guam and American Samoa on a list of 23 high-risk …
Director Blanco Emphasizes BSA Resource Sharing, Technological Innovation, and Collaboration Between Public and Private Sectors The Financial Crimes Enforcement Network (FinCEN) released prepared remarks delivered by FinCEN director, Kenneth A. Blanco, at the Securities Industry and Financial Markets Association (SIFMA) Anti-Money Laundering (AML) & Financial Crimes Conference on February 4, 2019. Director Blanco’s speech highlights various regulatory reform efforts, including the approval of collaborative sharing of Bank Secrecy Act (BSA) resources and an interagency initiative…
“V-bucks,” the in-game virtual value currency of the wildly popular video game, Fortnite, is reportedly being used to launder the proceeds of stolen credit cards. An investigation by The Independent reveals that discounted V-bucks are being sold in surprisingly large quantities on the dark web – the relatively hidden section of the internet only accessible using special software. Yet these purportedly ill-gotten gains are also being spread throughout the open web, albeit on a smaller…
Typical Virtual Currency Exchanges Do Not Require PA Money Transmitter Licenses The Pennsylvania Department of Banking and Securities (“DoBS”) just released Guidance declaring that virtual currency, “including Bitcoin,” is not considered “money” under the Pennsylvania Money Transmission Business Licensing Law, otherwise known as the Money Transmitter Act (“MTA”). Therefore, according to the Guidance, the operator of the typical virtual currency exchange platform, kiosk, ATM or vending machine does not represent a money transmitter subject…
As we have blogged, courts have held that financial institutions generally do not owe a duty of care to a noncustomer and that no special duty of care arises from the duties and obligations set forth in the Bank Secrecy Act (“BSA”), absent a special relationship or contractual relationship. Moreover, there is no private right of action stemming from the BSA. Nor does the BSA define a financial institution’s standard of care for the…
Former Bankers Allegedly Concealed “Master of Kickbacks” from Internal Compliance Department A detailed indictment unsealed on January 3 in the Eastern District of New York alleges that former Credit Suisse bankers, a Lebanese businessman, and former top officials in Mozambique, including the former Minister of Finance, participated in a $2 billion corruption, fraud and money laundering scheme (“the Indictment”). The defendants, including three former members of Credit Suisse’s Global Financing Group, face charges of conspiracy…
On December 7 and 10, 2018, the Financial Action Task Force (“FATF”) released two reports evaluating the United Kingdom’s (“UK”) and Israel’s anti-money laundering (“AML”) and counter-terror financing (“CTF”) programs and welcomed Israel as the 38th member of the task force. The FATF is an inter-governmental policymaking body dedicated to creating AML standards and promoting effective measures to combat money laundering (“ML”) and terrorist financing (“TF”). When releasing both reports, the FATF described the UK and…
As reported in Reuters and other media outlets, the partial government shutdown has impaired the ability of the U.S. Treasury to maintain many of its anti-money laundering and counter-terrorist financing (“AML/CTF”) efforts.  Specifically, the Financial Crimes Enforcement Network (“FinCEN”), the Office of Foreign Assets Controls (“OFAC”) and the Office of Terrorism and Financial Intelligence (“TFI”) have implemented a “lapse in appropriations contingency plan.” Reuters summarizes the situation regarding FinCEN and OFAC as follows, and provides links to…
Government Alleges that Broker Dealer Ignored Major Red Flags Raised by Pay Day Lending Scheme For the first time, a broker-dealer, Central States Capital Markets, LLC (Central States), has been prosecuted for violating the Bank Secrecy Act (BSA). Central States stipulated to the accuracy of a deferred prosecution agreement‘s (DPA) Statement of Facts, which detailed significant failures to comply with its customer identification procedures (CIP), failures to investigate and file Suspicious Activity Reports (SARs),…