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

On Oct. 11, 2019, the Financial Crimes Enforcement Network (FinCEN), the U.S. Commodity Futures Trading Commission (CFTC), and the U.S. Securities and Exchange Commission (SEC), published a Joint Statement on
Continue Reading CFTC, FinCEN and SEC Issue Joint Statement Reminding Persons in Digital Assets Space of Obligations Under Bank Secrecy Act

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