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THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Tag Archives: anti-money laundering

Anti-Money Laundering

Bank Secrecy Act’s Anti-Money Laundering and Counter Terrorism Financing Requirements to Apply to Investment Advisers

The Bank Secrecy Act (“BSA”) establishes program, recordkeeping, and reporting requirements for certain financial institutions to combat and detect money laundering, terrorist financing, and other illicit activities.  On February 13, 2024, FinCEN proposed new rules which expand the scope of the BSA to include certain investment advisers, which currently are not subject to any federal… Continue Reading
Anti-Money Laundering, Enforcement and Prosecution Policy and Trends, Securities and Commodities

SEC Opens Cease-and-Desist Order Proceeding against Broker-Dealer and Chief Compliance / AML Officer

As we have highlighted in prior posts, regulators of financial institutions, including FinCEN, FINRA and SEC, have increasingly brought actions to bring organizations – and individuals – into compliance with AML / BSA obligations.  This enforcement activity is consistent with FinCEN’s August 2014 Advisory, now nearly three years old, emphasizing the idea that U.S. financial institutions… Continue Reading
Anti-Bribery and Corruption, Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends

UK set to shake up Corruption and Money Laundering Enforcement

The UK Government introduced the Criminal Finances Bill to Parliament today (13 October 2016), which will now start its passage through the parliamentary approval process before becoming law. The Government hopes that the Bill “will significantly improve the government’s ability to tackle money laundering and corruption, recover the proceeds of crime, and counter terrorist financing”, and… Continue Reading
Anti-Bribery and Corruption, Anti-Money Laundering, Compliance

The Anti-Corruption Summit – UK plans for further corporate criminal offences, and a host of other proposals

The UK’s Prime Minster David Cameron has just hosted the  “Anti-Corruption Summit”, a first of its kind, bringing together world leaders, business, and civil society with the goal of seeking to agree on a package of steps to: Expose corruption so there is nowhere to hide Punish the perpetrator and support those affected by corruption Drive… Continue Reading
Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

FinCEN Announces Caesars Penalty After Multiyear Investigation

This week the Financial Crimes Enforcement Network (FinCEN) announced a Consent Agreement that imposed an $8 million civil penalty against Desert Palace, Inc. d/b/a Caesars Palace. Caesars first disclosed the investigation in SEC filings in late 2013. The investigation grew out of a 2012 audit performed by FinCEN’s examiner, the Internal Revenue Service Small Business/Self-Employed… Continue Reading
Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

Casino Forfeiture a Reminder that FinCEN’s Regulatory Oversight May Involve DOJ and Criminal Penalty

In early June 2015, FinCEN assessed a civil money penalty on the Tinian Dynasty Hotel & Casino, located in the Northern Mariana Islands, an archipelago to the east of the Philippines (don’t feel bad if you click here to learn a little more). Being a U.S. territory, the Northern Marianas are subject to federal regulation.… Continue Reading
Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

FinCEN Reasserts its Commitment to Casino Oversight and Enforcement

In a recent post we described a number of steps taken over the last year by the primary federal regulator for casinos – the Financial Crimes Enforcement Network (FinCEN) – that should cause casino operators to have Title 31 and Bank Secrecy Act (BSA) compliance among their top priorities. Based on this FinCEN activity, the… Continue Reading
Anti-Bribery and Corruption, Anti-Money Laundering, Compliance, Enforcement and Prosecution Policy and Trends, Financial Institution Regulation

The Financial Services Authority continues its thematic reviews into anticorruption compliance – now it is the turn of asset managers

So far, since the Bribery Act came into force on 1st July 2011, the largest fines have been dished out by the FSA, which regulates the financial services sector in the UK, rather than by the courts… Continue Reading

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