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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On December 1, 2016, the Financial Action Task Force (“FATF”) released a peer assessment of the United States’ anti-money laundering and combatting the financing of terrorism (“AML/CFT”) regime.  This is the first peer assessment of the United States since June 2006.

The FATF assessment found that the U.S. AML/CFT framework
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