On October 15, 2020, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) released its Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity (Supplemental Advisory). The last time FinCEN provided guidance on identifying trafficking in anti-money laundering (AML) processes was in Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial Red Flags on September 11, 2014. The evolving tactics of human traffickers and behaviors of victims required ...
By Barbara Meeks and Kristina Whittaker. Last month the Financial Crimes Enforcement Network (FinCEN) and the federal bank regulators issued a Joint Statement aimed at improving transparency into their risk-focused examination and supervision of banks’ compliance with Bank Secrecy Act/Anti-money Laundering (BSA/AML) requirements.
The statement outlines common supervisory practices for assessing a bank’s BSA/AML risk profile, scope and planning of examinations and evaluating the adequacy of BSA/AML compliance programs. The risk-focused approach enables federal ...
By John Han and Katherine Lamberth. President Trump piqued the interest of participants in and observers of the marijuana industry when he stated in early June that he would “probably” support recently proposed bipartisan legislation aimed at removing the federal prohibition on certain marijuana-related activity. President Trump’s statement is significant because it:
- indicates presidential support for the bill, which other legislative attempts at reforming federal marijuana laws have generally lacked, and
- signals a shift from the strict enforcement position taken ...
In a series of interviews, speeches and other public releases, OCC Comptroller Joseph Otting has set out a number of priorities, some substantive, some related to how the agency operates. It is clear that Mr. Otting intends to roll back or “modernize” regulations that have been viewed as burdensome or ineffective by the financial industry. In addition, he intends to make changes to the agency in ways that pull back on the Washington-centric structure and puts more authority in the hands of local supervisors. All of these are works in progress and some require action and/or ...
By Neil Bloomfield and Nathan White. After the Panama Papers exposed efforts by wealthy individuals and government officials to hide funds offshore, government authorities around the world have responded with new legislation, regulations and enforcement actions that are beginning to reshape the landscape for anti-money laundering (AML) and Bank Secrecy Act (BSA) violations. This post will be the first in a series of updates as the world begins to redefine these issues and what that means for companies that need to comply with the new standards.
United States
In some areas, the ...
About MVA White Collar Defense, Investigations, and Regulatory Advice Blog
As government authorities around the world conduct overlapping investigations and bring parallel proceedings in evolving regulatory environments, companies face challenging regulatory and criminal enforcement dynamics. We help keep our clients up to date in these fast-moving areas and to serve as a thought leader.
MVA White Collar Defense, Investigations, and Regulatory Advice Blog Updates
- DOJ CONTINUES EFFORTS TO ENCOURAGE VOLUNTARY CORPORATE SELF-DISCLOSURE WITH NEW SAFE HARBOR POLICY
- Takeaways from the 2023 South Asian Bar Associate Conference
- The Federal Reserve, FDIC and OCC Issue Final Guidance on Risk Management in Third-Party Relationships
- Tanisha Palvia and Alli Davidson co-author article: SCOTUS clarifies intent requirement for False Claims Act cases