We are very fortunate to have Nick St. John, Director of Federal Compliance at America’s Credit Unions, as our guest speaker in this podcast on the Notice of Proposed Rulemaking issued by the Financial Crimes Enforcement Network and federal banking regulators regarding the enhancement and modernization of anti-money laundering/countering the financing of terrorism (“AML/CFT”) compliance programs under the Bank Secrecy Act (“BSA”).… Continue Reading
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Three Members of Congress and U.S. Treasury Express Concerns that Florida Law Prohibiting Banks from Considering Customers’ Business Sectors or Political or Religious Beliefs Conflicts with Federal AML/CFT Requirements
As we previously blogged, a Florida law (Fla. Stat. § 655.0323, entitled “Unsafe and unsound practices”) which became effective July 1, 2024 prohibits federal and state depository institutions conducting business in the state from denying services based on religion or political beliefs and activities. Every year, financial institutions must attest to their compliance with the Florida law.… Continue Reading
BSA Filings and Their Utility to Law Enforcement: An Industry Viewpoint
Second in a Two-Part Series on the Utility of BSA Filings
In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime.
In our first blog post in this series, we invited Don Fort, a former Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division, to answer questions on utility of BSA filings from the perspective of law enforcement. … Continue Reading
BSA Filings and Their Utility to Law Enforcement: A Guest Blog
First in a Two-Part Series on the Utility of BSA Filings
Today we are very pleased to welcome guest blogger, Don Fort, who is the Director of Investigations at Kostelanetz LLP, and the past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division.
As Chief of IRS-CI from 2017 to 2020, Don led the sixth largest U.S.… Continue Reading
FinCEN issues advisory on COVID-19 and imposter and money mule schemes
The Financial Crimes Enforcement Network (“FinCEN”) just issued another Advisory pertaining to two consumer fraud schemes exacerbated by the COVID-19 pandemic. This Advisory focuses on “imposter schemes” and “money mule schemes, ”which we discuss below.
This most recent Advisory is the latest in a string of pronouncements relating to the pandemic by FinCEN, which has stated that it regularly will issue such documents. … Continue Reading