On October 11, 2018, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a lengthy “Advisory on the Iranian Regime’s Illicit and Malign Activities and Attempts to Exploit the Financial System,” (the “Iran Advisory”), which provides examples and typologies of the Iranian regime’s exploitation
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The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators have taken a small step towards improving the BSA/AML compliance framework for depository institutions.  These agencies issued a Joint Statement on Banks and Credit Unions Sharing Resources to Improve Efficiency and Effectiveness of Bank Secrecy Act Compliance
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Financial services regulatory reform in 2018 continues to evolve.  As we leave summer behind, here is the Fall Focus edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas, agencies and actors.  We will continue to track these issues and will
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In response to feedback from financial institutions, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Ruling granting exceptive relief (the Ruling) on September 7, 2018 to covered financial institutions from certain obligations under its beneficial ownership regulation, 31 C.F.R. § 1010.230 (the
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Financial services regulatory reform in 2018 continues to evolve.  For those of you who have been thinking you might catch up over the summer lull, here is the summer beach read edition of our reference tool, which provides context and summarizes current developments across a range of key regulatory areas,
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The banking sector should pay close attention to the recent bipartisan bill supporting marijuana legal reform (the “Strengthening the Tenth Amendment Through Entrusting States Act” or the “STATES Act”) given the increasing difficulty current law creates even for those banks that are deliberately avoiding the cannabis sector.  Post mid-term elections,
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On May 11, 2018, the customer due diligence rule, 31 C.F.R. § 1010.230 (the “CDD Rule”), issued by the Financial Crimes Enforcement Network (“FinCEN“) became applicable two years after it was issued.  The CDD Rule added a new requirement for covered financial institutions to identify,
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The past few days have seen several interesting developments in the law and regulation of digital tokens.  Each action reflects an intense focus by U.S. regulators to clarify the treatment of digital tokens, from those issued by startups in initial coin offerings (ICOs) to the more “traditional” cryptocurrencies
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In its first hearing of the year, the Senate Committee on Banking, Housing, and Urban Affairs expressed support for potential reforms to the U.S. anti-money laundering (“AML”) and countering the financing of terrorism (“CTF”) framework.  The hearing focused on the relationships among financial institutions, regulators, and
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2017 Enforcement Trends: Mid-Year Review

Please join us for a discussion on some of this year’s key enforcement trends and developments in U.S. Sanctions and Anti-Money Laundering.

  • Trends and expectations of the new Administration
  • Notable developments in U.S. sanctions programs
  • Review of AML initiatives
  • Recent enforcement actions

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