In response to the COVID-19 pandemic, the Financial Crimes Enforcement Network (FinCEN) on March 16, 2020, issued guidance asking regulated financial institutions to contact FinCEN and their functional regulator as soon as practicable if they have concerns that the pandemic may delay filings required by the Bank Secrecy Act (BSA). The guidance implicitly recognizes the
Caroline Brown Joins Crowell & Moring
Former U.S. Treasury and Justice Department Lawyer Strengthens Anti-Money Laundering, Economic Sanctions, and CFIUS Practices
Washington, D.C. — February 20, 2020: Crowell & Moring is bolstering its anti-money laundering, economic sanctions, and CFIUS practices with the addition of Caroline Brown, former attorney in the U.S. Department of the Treasury and the U.S. Department of
FinCEN Identifies Iran as Money Laundering Threat While OFAC Announces New Mechanism to Facilitate Humanitarian Assistance There
On Friday, October 25, 2019 the Financial Crimes Enforcement Network (FinCEN) issued a final rule pursuant to Section 311 of the USA PATRIOT Act finding Iran to be a jurisdiction of primary money laundering concern and imposing special measures prohibiting U.S. financial institutions from maintaining correspondent accounts for or on behalf of Iran. Separately on
Crowell & Moring Welcomes: Nicole Succar, Nimrah Najeeb, and Walter “Sam” Boone
Nicole Succar is a Counsel in Crowell & Moring’s International Trade Group and a resident in the firm’s New York office. She joins Crowell after serving as a senior vice president and head of U.S. economic sanctions advisory, and previously a vice president in the financial crimes division for HSBC, one of the world’s largest
On Demand Webinar: Global Workforce Compliance – What Every International Employer Should Know
Companies that conduct business internationally may become entangled in cross-border employment issues that often seem complicated because of the interaction between U.S. laws and potentially unfamiliar laws in the foreign country. In some cases, obligations may arise even when the company does not have “employees” on the ground. During this webinar, our attorneys discuss circumstances
OFAC Puts Shipping Community on Notice with Updates and Expanded Guidance
Over the last week, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has issued two updated advisories, as well as issued a series of new designations of Specially Designated Nationals (SDNs), highlighting the sanctions-related risks for, and the focus on, the shipping community. Taken together, they provide important guidance for
FinCEN and Federal Banking Agencies Encourage Innovative Approaches to BSA/AML Compliance
On December 3, 2018, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), the National Credit Union Administration, and the Office of the Comptroller of the Currency (together “the agencies”), issued a joint statement encouraging banks
Agencies Issue Joint Statement on Banks’ Resource Sharing and Collaborative Arrangements
On October 3, 2018, the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) (collectively, “the Agencies”) issued a statement addressing instances in which banks can collaborate
Banking Regulators Issue Exemption from CIP Requirements for Premium Finance Loans
On September 28, 2018, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively the Federal Banking Agencies or FBAs), with the concurrence of the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), issued an interagency order
New Obligation for Belgian Entities to Register Ultimate Beneficial Owners by March 31, 2019
In 2015, the European Union adopted its Fourth Anti-Money Laundering Directive, which imposed on Member States the obligation to establish a register containing the details of the ultimate beneficial owners (UBOs) of corporate and other legal entities within the European Union (the so-called UBO register). By way of the Act of September 18, 2017, the