Siana Danch

Siana Danch | danchs@ballardspahr.com | 215.864.8348 | view full bio

Siana focuses on regulatory compliance and enforcement, white collar defense, internal investigations, tax controversy and complex civil litigation. She advises financial institutions and other businesses on BSA/AML compliance, including issues relating to KYC, beneficial ownership reporting, Suspicious Activity Report filings, Travel Rule compliance, Form 8300 filings, and other BSA/AML reporting and record keeping requirements. Her work in the AML space includes the digital asset industry and related licensing requirements involving federal and state money-transmitter laws. Similarly, Siana represents financial institutions, other businesses and individuals in regards to conducting internal corporate investigations and defending against government criminal and civil investigations and proceedings, including as to allegations of fraud, money laundering, tax violations, and BSA/AML violations. She also represents clients in tax controversy cases, from audit to IRS appeals to litigation.

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FinCEN Issues Small Entity Compliance Guide for Corporate Transparency Act

By Peter D. Hardy, Scott Diamond, Siana Danch & Kaley Schafer on September 26, 2023

Posted in Attorney General Privilege, Attorney Liability, Beneficial Ownership, Corporate Transparency Act, Financial Crimes Enforcement Network (FINCEN)

The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as updated FAQs regarding CTA compliance.

The Guide contains six chapters and an appendix. It is 56 pages long. It appears to be useful to its apparent target audience, which is small businesses confronting relatively simple issues under the CTA.… Continue Reading

OCC targets BSA/AML compliance by Anchorage Digital Bank – only 15 months after granting bank charter to the crypto custodian

By Siana Danch on April 25, 2022

Posted in BSA/AML, Crypto, OCC

The Office of the Comptroller of the Currency entered into a Consent Order with Anchorage Digital Bank (“Anchorage”), which requires Anchorage to create a compliance committee and take steps to remediate alleged shortcomings with respect to the implementation and effectiveness of Anchorage’s Bank Secrecy Act/Anti-Money Laundering (“BSA/AML”) program. Notably, Anchorage will pay no civil penalty.