Statute
BSA
13 published works
Consumer Financial Services Law Monitor
The Debanking Debate: Regulators, Risk, and Reality for Payments
By Chris Willis, Keith J. Barnett, Carlin McCrory
In this special crossover episode of The Consumer Finance and Payments Pros podcasts, Carlin McCrory, Keith Barnett, and Chris Willis explore the federal government's increasing attention to "debanking" and what…
Consumer Financial Services Law Monitor
The Debanking Debate: Regulators, Risk, and Reality for Payments
By Keith J. Barnett, Chris Willis, Carlin McCrory
In this special crossover episode of Payments Pros and The Consumer Finance podcasts, Carlin McCrory, Keith Barnett, and Chris Willis explore the federal government's increasing attention to “debanking” and what…
Money Laundering Watch
FinCEN Imposes $3.5 Million Civil Penalty Against Paxful for BSA Violations
In December, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a $3,500,000 civil penalty against Paxful, Inc. and Paxful USA, Inc. (“Paxful”), pursuant to a consent order. Paxful…
Consumer Finance and Fintech Blog
NYDFS and Other State Regulators Impose $4.2 Million Penalty on Money Transmitter
By A.J. Dhaliwal, Mehul Madia, Maxwell Earp-Thomas
On July 9, the New York Department of Financial Services (NYDFS), joined by regulators from five other states, entered into a multistate settlement with a money transmitter headquartered in New…
Money Laundering Watch
BSA Filings and Their Utility to Law Enforcement: A Guest Blog
By Peter D. Hardy, Siana Danch
First in a Two-Part Series on the Utility of BSA Filings Today we are very pleased to welcome guest blogger, Don Fort, who is the Director of Investigations at Kostelanetz…
Money Laundering Watch
FinCEN Releases Year-in-Review for FY 2023: SARs, CTRs and Information Sharing
By Peter D. Hardy, Siana Danch
The Financial Crimes Enforcement Network (“FinCEN”) has issued its Year in Review for FY 2023 (“YIR”). It consists of five pages of infographics. According to FinCEN’s press release: The Year…
Money Laundering Watch
PLI Anti-Money Laundering Conference to Address Key Issues in BSA/AML
Enforcement Trends, Gaming, Crypto — and More I am very pleased to co-chair again the Practicing Law Institute’s 2024 Anti-Money Laundering Conference on May 23, 2024, starting at 9 a.m.…
Money Laundering Watch
FinCEN Issues Alert on COVID-19 Employee Retention Tax Credit Fraud
On November 22, 2023, the Financial Crimes Enforcement Network (“FinCEN”), in close coordination with the Internal Revenue Service (“IRS”) Criminal Investigation (“CI”), issued an alert (“Alert”) regarding the COVID-19 Employee…
Bank Law Monitor
At Long Last, FinCEN Offers Much Awaited Guidance Regarding BSA Due Diligence Requirements for Hemp Businesses
Ever since Congress passed the 2018 Farm Bill and hemp was declassified under federal law as a Schedule I controlled substance, financial institutions have struggled with whether and how to…
Money Laundering Watch
Former Bank General Counsel Enters into Consent Order Over Alleged AML Obstruction
The Office of the Comptroller of Currency (“OCC”) issued an extraordinary announcement regarding the decision of a former bank general counsel – Daniel Weiss, formerly employed by Rabobank, N.A. –…