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
FinCEN Announces New Global Investigations Division and New Leader for Liaison Division
On August 28, 2019 the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) announced the launch of a Global Investigations Division (GID), which will be led by Matthew Stiglitz, a former Principal Deputy Chief in the Department of Justice’s (DOJ’s) Criminal Division. The GID replaces and expands on FinCEN’s Office of Special Measures (OSM),
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
FinCEN Issues Revised GTOs Including Lower Purchase Thresholds and Virtual Currencies
On November 15, 2018, FinCEN issued revised Geographic Targeting Orders (GTOs), once more expanding its scrutiny of “all-cash” purchases (i.e., those without bank loans or other external financing) in the luxury residential real estate market. FinCEN broadened the geographic scope of the orders, lowered the purchase amount threshold for each covered area,
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
FinCEN Grants Rollover and Renewal Exception to Beneficial Ownership Requirement
On September 7, 2018, the Financial Crimes Enforcement Network (FinCEN) granted exceptive relief to “covered financial institutions”—banks, broker-dealers, mutual funds, and introducing brokers in commodities—from the requirement to identify and verify the identity of the beneficial owner(s) of their legal entity customers when those customers open a new account as a result of the following:
Now Available On Demand – Webinar Trade in 2018 – What’s Ahead?
On April 19, Crowell & Moring’s International Trade Attorneys hosted a webinar on “Trade in 2018 – What’s Ahead?”
Please click here to register and view the webinar on demand.
Summary
From the Section 232 national security tariffs on steel and aluminum imports to the ongoing NAFTA re-negotiation, the Trump administration is seeking to implement
PODCAST: Venezuela and Cross-Border Issues
Venezuela has frequently been in the news lately, not only because of domestic politics, but also because of sanctions and bribery enforcement actions brought by U.S. authorities. In this podcast, Crowell & Moring’s Cari Stinebower, Dalal Hasan, Eduardo Mathison, and Mariana Pendás provide an overview of recent political and enforcement developments in Venezuela and explain
U.S. BANK ASSESSED $185 MILLION PENALTY FOR VIOLATING BANK SECRECY ACT
On February 15, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in coordination with the Office of the Comptroller of the Currency (OCC), and the U.S. Department of Justice (DOJ), announced the assessment of a $185 million civil money penalty against U.S. Bank for willful violations of several provisions of the Bank
FINCEN NAMES LATVIAN BANK PRIMARY MONEY LAUNDERING CONCERN – PROPOSES SECTION 311 SPECIAL MEASURE
On February 13, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a finding pursuant to Section 311 of the USA PATRIOT Act identifying ABLV Bank of Latvia as a “primary money laundering concern.” FinCEN also issued a notice of proposed rulemaking (NPRM) under that section which, if adopted, would prohibit financial