Archives: Anti-Money Laundering

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Treasury Announces Anti-Money Laundering, Corruption, and Tax Evasion Regulations and Legislation

On May 5, 2016, the US Department of the Treasury announced several actions to crack down on illicit financial conduct and increase transparency in the financial system.  First, Treasury will publish a Customer Due Diligence (“CDD”) Final Rule.  This rule will harmonize and clarify existing anti-money laundering due diligence requirements and also add a new … Continue Reading

FinCEN Reissues Final Rule Against FBME Bank

On March 25, 2016, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that it is reissuing a final rule against FBME Bank Ltd. (FBME).  Under Section 311 of the USA PATRIOT Act, FinCEN has authority to designate a foreign financial institution as a “primary money laundering concern” and promulgate a rule imposing “special measures” … Continue Reading

Smart Tools and Targeted Enforcement: FinCEN’s Increasing Use of Geographic Targeting Orders

The current leadership of the Financial Crimes Enforcement Network (FinCEN) aggressively has sought to close gaps in its anti-money laundering enforcement efforts.  We’ve blogged about some of FinCEN’s recent efforts (here and here) to broaden regulation and bring new types of enforcement actions.  Along similar lines is FinCEN’s increasing use of Geographic Targeting Orders (GTOs) … Continue Reading

FinCEN’s Expanding Enforcement in 2015

The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) was very active in the waning days of 2015.  And FinCEN’s message from this activity is clear – it is closing any gaps it finds in anti-money laundering (AML) enforcement, including for non-traditional financial institutions, not used to being the focus of regulation, but increasingly the choice … Continue Reading

Anti-Money Laundering Developments at FinCEN

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has been busy – both on offense and defense. In just the past few months, two foreign banks have filed novel lawsuits against FinCEN in response to draconian “Section 311” FinCEN actions against those banks. At the same time, FinCEN is broadening the reach of its anti-money … Continue Reading