The incoming Biden administration faces a number of serious international trade issues, including increased tensions with China, the implementation of Brexit, and last, but far from least, a global pandemic that continues to impact global supply chains, mobility, and many other aspects of our interconnected world. Join us as we identify these issues along with
Anti-Money Laundering (AML)
Congress Passes the Anti-Money Laundering Act of 2020, Significant Changes to the Bank Secrecy Act Ahead
On January 1, 2021, the Senate followed the House and voted to override President Trump’s veto of the National Defense Authorization Act for Fiscal Year 2021 (NDAA). As is typical, the NDAA touched on a wide range of legal areas, including numerous new government contracts requirements, as well as a number of sanctions and export…
FinCEN Issues ANPRM Seeking Comment on Requirement for an “Effective and Reasonably Designed” AML Program
On September 16, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued an advanced notice of rulemaking (“ANPRM”) requesting comments on proposed regulatory changes under the Bank Secrecy Act (“BSA”) that aim to enhance the effectiveness of anti-money laundering (“AML”) programs. The proposals reflect the recommendations of a working group within the Bank Secrecy Act Advisory…
Key Lessons Learned as UK’s AML Regulator Shows its Teeth
Only four months after the the United Kingdom’s Office of Financial Sanctions Implementation (OFSI) issued a £20.47 million penalty against Standard Chartered Bank (SCB) for alleged violations of the U.K.’s Ukraine- and Russia-related sanctions (see our alert here), another bank is in the news for regulatory breaches. This time it is the London…
Industrial Bank of Korea Agrees to a Deferred Prosecution Agreement and $86 Million in Penalties for Violations of the Bank Secrecy Act That Allowed Evasion of Sanctions on Iran
On April 20, 2020, the U.S. Attorney for the Southern District of New York (SDNY) announced that the Industrial Bank of Korea (IBK) agreed to a deferred prosecution agreement (DPA) and $51 million penalty related to a one-count felony information charging IBK with violating the Bank Secrecy Act (BSA). On the same day, the New…
Webinar: Emerging Issues in Sanctions, AML and Everything in Between in the Time of COVID-19: 2020 AML & Sanctions Risk Considerations for Digital Assets Companies
May 19, 2020
Starts: 9:30 AM (EDT)
Ends: 10:30 AM (EDT)
For Crowell & Moring LLP’s next event in our series, Emerging Issues in Sanctions, AML, and Everything in Between in the Time of COVID-19, our Global Head of Blockchain & Digital Assets, Michelle Gitlitz, will moderate a discussion on the AML & Sanctions risks…
Webinar: Emerging Issues in Sanctions, AML and Everything in Between on Tuesday, April 28 at 10:00 am EDT
As part of Crowell & Moring’s ongoing effort to keep clients informed about the most significant developments stemming from the COVID-19 pandemic, we are offering a webinar series focused on issues that are immediate in terms of their impact, as well as issues that are just around the corner. Our focus is helping clients to…
Anti-Money Laundering Program Contingency Planning during COVID-19: Recent Guidance from FinCEN and FFIEC
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…