We previously blogged about the Financial Crimes Enforcement Network’s (“FinCEN’s”) issuance on June 30 of the first government-wide list of priorities for anti-money laundering and countering the financing of terrorism (“AML/CFT”) (the “Priorities”), as required by the Anti-Money
Continue Reading FINRA Reminds Firms to Prepare for New AML/CFT Priorities
On October 15, 2021, the Financial Crimes Enforcement Network (“FinCEN”) issued a financial trend analysis on ransomware relating to Suspicious Activity Reports (“SARs”) filed in the first half of this year (“Analysis”). According to the Analysis, U.S. banks and financial
Continue Reading FinCEN Reports Spiraling SARs Relating to Ransomware
Meaningful Overlap or Superficial Similarities?
On October 3, the release of the Pandora Papers flooded the global media, as millions of documents detailed incidents of wealthy and powerful people allegedly using so-called offshore accounts and other structures to shield wealth
Continue Reading ESG, AML Compliance and the Convergence of Social Concerns
Lawmakers Targeted “Gatekeeper” Professions Following the Pandora Papers Leak
Motivated by revelations contained in the recently-released Pandora Papers, on October 6, 2021, four U.S. Representatives – Tom Malinowski (D-NJ), Maria Elvira Salazar (R-FL), Steve Cohen (D-TN), and Joe Wilson
Continue Reading The ENABLERS Act Seeks to Impose BSA/AML Requirements on an Array of “Middlemen” Professionals
On October 6, the Department of Justice (“DOJ”) announced the creation of a National Cryptocurrency Enforcement Team (“NCET”). The DOJ press release is set forth in part below, without further commentary, other than to observe that the NCET’s stated goals
Continue Reading DOJ Announces National Cryptocurrency Enforcement Team
Global AML Compliance Faces Challenges Relating to Regulator Expertise, the Travel Rule, Decentralized Finance, and “Regulator Shopping”
Today we are very pleased to welcome guest blogger Federico Paesano from the Basel Institute on Governance (“Basel Institute”). The Basel Institute recently
Continue Reading The Basel AML Index 2021: Virtual Assets and Money Laundering. A Guest Blog.
On September 23, the Financial Crimes Enforcement Network (“FinCEN”) issued an advance notice of proposed rulemaking (“ANPRM”) to solicit comment on questions related to the implementation of anti-money
Continue Reading FinCEN Solicits Comments on AML Rules for the Antiquities Trade
Second Post in a Two-Part Series on Recent OFAC Designations
As we blogged yesterday, OFAC has been busy. Right before OFAC designated the virtual currency exchange SUEX for allegedly facilitating ransomware payments, OFAC announced another significant but more traditional
Continue Reading OFAC Targets Alleged Funders of Hizballah Using Gold and Front Companies
OFAC Updates Advisory on Enforcement Risks Relating to Agreeing to Pay Ransomware
First Post in a Two-Part Series on Recent OFAC Designations
On September 21, 2021 OFAC issued its first sanctions designation against a virtual currency exchange by designating the
Continue Reading OFAC Targets Virtual Currency Exchange For Ransomware Attack
Today, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice regarding online child sexual exploitation. Given its brevity, its text is set forth below in its entirety, without the footnotes. There is a final section to the Notice, not included
Continue Reading FinCEN Calls Attention to Online Child Sexual Exploitation Crimes
