Archives: Anti-Money Laundering

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Trump’s Mexico Remittance Proposal Goes Inexplicably Awry

In one of Donald Trump’s first proposals with legal details – explaining the mechanism through which he would coerce Mexico to pay for a border wall – Trump has gotten those legal details embarrassingly wrong. It almost overshadows the incoherence of the proposal. In a March 31 memo addressed from Trump to Robert Costa and … 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
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