Tag Archives: AML

Financial Agencies Release Joint Statement on Innovative Efforts to Combat Money Laundering and Terrorist Financing

On December 3, 2018, the Board of Governors of the Federal Reserve System (“Federal Reserve), the Federal Deposit Insurance Corporation (“FDIC”), the Financial Crimes Enforcement Network (“FinCEN”), the National Credit Union Administration (“NCUA”), and the Office of the Comptroller of the Currency (“OCC”) (collectively, “agencies”) released a joint statement on innovative efforts to combat money … Continue Reading

Senate Testimony Highlights Tensions in BSA/AML Reform Efforts as Lawmakers Consider Bipartisan Legislation

Representatives of the Office of the Comptroller of the Currency (“OCC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Federal Bureau of Investigation (“FBI”) testified on Thursday, November 29 before the Senate Committee on Banking, Housing, and Urban Affairs (“Banking Committee”) on anti-money laundering (“AML”) issues. The testimony highlighted some tensions between the views of … Continue Reading

Australia and Malta Adopt Different Approaches to Cryptocurrency and Blockchain Regulation

The Australian Transaction Reports and Analysis Center (“AUSTRAC”) recently implemented a new regulation for digital currency exchange providers operating in Australia called the Anti-Money Laundering and Counter-Terrorism Financing (Digital Currency Exchange Register) Policy Principles 2018.  AUSTRAC is Australia’s financial intelligence agency and is responsible for the enforcement of Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act … Continue Reading

TCH Report on Redesign of the AML/CFT Regulatory Framework

The Clearing House published this week a report that highlights potential anachronisms and inefficiencies in current U.S. anti-money laundering / counter-financing of terrorism regulation.  The report makes 8 core recommendations for reform, including the following: Centralizing Regulatory Responsibility:  “The Department of Treasury, through its Office of Terrorism and Financial Intelligence (TFI), should take a more … Continue Reading

Financial Stability Board Publishes 2017 Roadmap for Correspondent Banking

On December 19, 2016, the Financial Stability Board (“FSB”) issued its end-of-2016 progress report regarding its action plan to assess and address the decline in correspondent banking. The report sets out a roadmap the FSB intends to follow in 2017 in response to the decline of correspondent banking, a critical part of the global payments … Continue Reading

Post-Election Outlook for Financial Regulatory Agencies: Financial Crimes Enforcement Network

President-Elect Donald J. Trump has said little about his plans for money laundering and terrorist financing enforcement, or his plans for the agency responsible for many of the Federal government’s anti-money laundering (“AML”) initiatives, the Financial Crimes Enforcement Network (“FinCEN”). FinCEN is a bureau within the Treasury Department and not a fully independent agency.  Its … Continue Reading

FinCEN Issues Advisory on Suspicious Activity Reporting Requirements for Cyber-attacks Under the Bank Secrecy Act

On October 25, 2016, the Financial Crimes Enforcement Network (FinCEN) issued an Advisory to financial institutions to (i) clarify reporting requirements under the Bank Secrecy Act (BSA) for filing Suspicious Activity Reports (SARs) on cyber-attacks and cyber-enabled crimes, (ii) note what information financial institutions should include in such reports, and (iii) encourage financial institutions to share … Continue Reading

OCC Releases De-Risking Guidance for Foreign Correspondent Banking

On October 5, 2016, the Office of the Comptroller of the Currency (“OCC”) issued guidance to national banks, federal savings associations, and federal branches and agencies regarding their periodic evaluation of the risks related to foreign correspondent accounts.  The guidance appears aimed to address widely reported concerns that financial institutions are unnecessarily terminating relationships with … Continue Reading
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