ISIS puts terrorist financing back on global political agenda

Tweet The key issue at the International Conference on Peace and Security in Iraq today was terrorist financing – how the ISIS got to be financed thus far and how to disrupt its financing. The Conference, convened by the President of France and of Iraq, was convened to discuss ways to deal with the growing threat […]

Bankrupting the banks? Historic trial may find financial institutions liable for the terrorist acts of customers

Tweet Banks and financial institutions around the world are closely watching the Linde v. Arab Bank case unfold in New York City. It’s the first civil trial against a bank for alleged violations of the AntiTerrorism Act of 1990 (“ATA“), 18 USC 2331. The litigation seeks to hold the Arab Bank, a third party, liable for injuries resulting from acts […]

Casino employee fined by FinCEN over anti-money laundering compliance issues

Tweet The Financial Crimes Enforcement Network (“FinCEN“) has fined a former manger of a US casino over anti-money laundering compliance violations. According to the Wall Street Journal, George Que, a former manger of VIP services at Tinian Dynasty Hotel & Casino, assisted high rollers at the casino to gamble outside of the Bank Secrecy Act […]

FINRA ramps up anti-money laundering compliance actions at securities firms

Tweet The Financial Industry Regulatory Authority (“FINRA“) announced today that it filed a  Complaint against Wedbush Securities Inc. for alleged egregious and systemic anti-money laundering compliance infractions. According to the Wall Street Journal’s Risk & Compliance Journal, FINRA has made enforcement of securities anti-money laundering a priority. According to securities firms in Toronto, so have […]

PwC settles with New York bank regulator over anti-money laundering and sanctions advice

Tweet The New York Department of Financial Services (“NYDFS“) has announced that it has entered into a settlement with the advisory firm of PricewaterhouseCoopers Regulatory Advisory Services (“PwC“) over anti-money laundering and sanctions compliance advice it provided to the Bank of Tokyo Mitsubishi (“Bank of Tokyo“). PwC is suspended for two years from accepting consulting […]

New beneficial ownership rules in the US to require disclosure of shareholders of private entities in a move towards G20/G8 financial transparency

Tweet New Beneficial Ownership Rules FinCEN has released draft rules under the Bank Secrecy Act to identify the legal and beneficial shareholders (the natural persons) of private corporate entities (also known as legal persons). In other words – the disclosure of natural persons involved in all legal persons. The rule will take effect within a year after […]

US banks driving improved money laundering controls at casinos

Tweet Banks driving compliance changes By Christine Duhaime, B.A., J.D., Financial Crime and Certified Anti-Money Laundering Specialist Follow @cduhaime According to this story in Reuters, banks in the US are reluctantly driving American casinos towards greater anti-money laundering compliance. Casinos are bank clients and pursuant to anti-money laundering legislation, banks have to monitor their clients’ transactions […]

Standard Chartered Plc completing massive “look back” program

Tweet Months of Look Backs Required By Christine Duhaime, B.A., J.D., Financial Crime and Certified Anti-Money Laundering Specialist Follow @cduhaime According to this article in Reuters, as a result of non-functioning anti-money laundering software, Standard Chartered Plc will be undertaking the monumental task of reviewing millions of processed transactions to determine if such transactions should have […]

Thoughts on FinCEN Director’s speech on bank de-risking and the refusal of banking services to MSBs (and by implication, Bitcoin)

Tweet De-risking that results in unbankable businesses  By Christine Duhaime, B.A., J.D., Financial Crime and Certified Anti-Money Laundering Specialist Follow @cduhaime In a speech delivered to the anti-money laundering legal and law enforcement community, the Director of FinCEN, Jennifer Shasky Calvery, made some interesting and compelling comments that touch on the economic costs of anti-money laundering (“AML“) […]

Aligning FATCA with the AML compliance regime

Tweet It has been noted by US officials that the Foreign Account Tax Compliance Act (“FATCA“), 26 USC Ch. 4, is not only one of the most significant pieces of US legislation for financial institutions, asset managers and foreign residents, it is also one of the most legally complex and technical that “will spawn significant enforcement activity […]