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RESULTS FOR: BSA

Enhanced Due Diligence on Potential Clients is Increasing in Importance for Law Firms

September 29, 2022 | Due Diligence Financial Crime Consulting

Regulatory trends and high-profile investigations suggest that law firms should conduct enhanced due diligence background checks on all potential clients as part of standard risk management and compliance protocols.  

The U.S. House of Representatives recently passed anti-money laundering legislation that would require law firms (in addition to accountancies, payment service providers, and trust companies) to report suspicious transactions by clients, as banks already must do. 

Despite industry push back and arguments by some that the affirmative reporting obligations would negatively Read More

Bank Secrecy Act Modernization Likely to Increase BSA/AML Enforcement, Including From Larger Whistleblowing Awards

January 13, 2021 | Financial Crime Consulting

2020 saw a substantial amount of enforcement activity in the BSA/AML/OFAC area.   Even prior to last month’s enactment of the Anti-Money Laundering Act of 2020 (the “2020 AMLA”), conventional wisdom favored an increase in enforcement activity by regulators and prosecutors for violations of laws in these areas under the incoming Biden Administration. [See Division F]

The 2020 AMLA just gave this area of enforcement a significant shot in the arm.  In an era where federal legislation has become … Read More

Combating Money Laundering and Terrorist Financing in the Art Community

April 7, 2020 | Compliance Financial Crime Consulting

Although perhaps not as brazen as the recent theft of a Van Gogh from a museum in the Netherlands, fine art can be an attractive target for accused money launderers like Nazem Said Ahmad. Mr. Ahmad was recently named a “designated person” by the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC). OFAC pointed to the use of a Beirut art gallery by Ahmad to launder money in support of Hizballah (a/k/a Hezbollah) just as it issued … Read More

Out of Many, One? — The Future of U.S. FinTech Regulation

October 2, 2018 | Compliance Financial Crime Consulting

As published in FinTechWeekly August 29, 2018.

Not for the first time, the federal government and states are at odds over the future regulation of FinTech.

On July 31, 2018, the Office of the Comptroller of Currency (OCC) at the U.S. Department of the Treasury (DoT) announced it would begin accepting applications from FinTechs for special bank charters, which would allow them to operate nationally. But individual states and inter-state organizations are strongly opposed. The Conference of State Bank Supervisors … Read More

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