As another sign of the times, but arguably quite apt given the subject matter, the Consensus Blockchain Conference convened virtually in 2020, with Financial Crimes Enforcement Network (FinCEN) Director Ken


Continue Reading FinCEN Director Confirms Enforcement Focus on Virtual Currency AML Compliance

In the last decade, traditional financial institutions such as banks and broker-dealers have faced increased scrutiny from federal regulators and prosecutors related to the adequacy of their anti-money laundering (AML)
Continue Reading AML Compliance Scrutiny of Virtual Currency Services in 2020 and Beyond

Unexplained Wealth Orders (UWOs) extend the powers available to UK law enforcement authorities under the Proceeds of Crime Act 2002 (POCA), enabling investigators to ask people who are holding assets,
Continue Reading Prove It or Lose It! Parts I and II: Unexplained Wealth Orders and Civil Recovery Orders in the United Kingdom

On August 2, 2017, United States Senators Marco Rubio (R-FL) and Ron Wyden (D-OR) jointly introduced Senate Bill 1717, entitled the “Corporate Transparency Act of 2017” (the “Act”).  The Act
Continue Reading New Bill Introduced in the U.S. Senate to Require the Disclosure of Ultimate Beneficial Owners of Corporations and LLCs Formed or Registered in the United States

On July 23, 2015, the Office of Management and Budget (OMB) completed its review of a proposed regulation submitted to OMB by the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of the Treasury that, when finalized into a final regulation, would require investment advisers to adopt and implement anti-money laundering (AML) program and file suspicious activity reports (SARs). The clearance by the OMB means a proposed AML program/SAR regulation for investment advisers could be published by FinCEN as early as within the next several weeks. It remains unclear whether such publication would resuscitate the prior FinCEN proposals of over a decade ago which would have required unregistered investment companies and commodities trading advisers to adopt an AML program. 
Continue Reading Proposed AML Program and SAR Reporting Requirements Nearing for Investment Advisers

In recent months, certain small banks have come under increased investigation by FinCEN, federal bank regulators, and in some instances the Department of Justice (DOJ) for alleged non-compliance with the
Continue Reading Recent DOJ and Regulatory Actions Against Smaller Institutions Suggest That Community Banks Should Continue to Carefully Consider BSA/AML Risks