Anti-Money Laundering (AML)

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced today that it has launched a new Global Investigations Division (GID), which will be responsible for implementing targeted investigation strategies to combat illicit finance threats and related crimes, both domestically and internationally. Matthew Stiglitz, a former Principal Deputy Chief in the Department of Justice’s Criminal Division,

Last week, the Financial Crimes Enforcement Network (FinCEN) announced its first-ever civil penalty against a cryptocurrency exchanger for willful violations of the Bank Secrecy Act (BSA). According to the FinCEN Assessment of Civil Money Penalty (Assessment), California-based Eric Powers failed to register with FinCEN as a money services business (MSB); develop, implement, and maintain an

Our colleagues Joshua Horn, Ernest E. Badway, and Benjamin H. McCoy have published an article about the recent release by the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations of its 2018 examination priorities, an annual report outlining the areas of the securities industry its examiners will target. This year, the

Today the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that it had fined a California card club, Artichoke Joe’s Casino, $8 million for numerous willful violations of the Bank Secrecy Act occurring since 2009. In its assessment, FinCEN found that during the last eight years, the card club failed to implement and maintain

BitcoinIn its recently-published 2017 National Drug Threat Assessment (NDTA), the Drug Enforcement Administration reports that drug trafficking organizations are turning to Bitcoin and other virtual currencies to enable easy transfer of illicit funds internationally. The NDTA is a comprehensive strategic assessment of the threat posed to the United States by domestic and international drug trafficking

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued an advisory to alert financial institutions of widespread public corruption in Venezuela and the methods Venezuelan senior political figures and their associates may use to move and hide proceeds of their corruption through the U.S. financial system. The advisory also describes a number of financial

This article is Part II of a series in which we address the U.S. government’s attempts to combat money laundering in real estate transactions. Part I is available here.

On August 22, 2017, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued revised Geographic Targeting Orders (GTOs) requiring title insurance companies, and their subsidiaries

This article is Part I of a series in which we address the U.S. government’s attempts to combat money laundering in real estate transactions.

This week the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that it was both extending and broadening its anti-money laundering efforts in the luxury real estate area to capture a

Today the Financial Crimes Enforcement Network (FinCEN) announced the issuance of revised Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used to pay for high-end residential real estate in seven metropolitan areas.  (For prior blog coverage, see here and here.)  Following the recent enactment

Over at the In The Weeds blog (which explores developments in cannabis law and business), Melissa T. Sanders writes about the recent publication by the Treasury Department’s Financial Crimes Enforcement Network of its “Marijuana Banking Update.”  In this publication, FinCEN summarizes the number of depository institutions providing banking services to marijuana-related businesses in