The Financial Crimes Enforcement Network (FinCEN) released guidance on the Bank Secrecy Act (BSA) and anti-money laundering (AML) obligations and considerations surrounding hemp-related customers. These customers include hemp growers, and processors and manufacturers that purchase hemp from such growers. The Guidance supplements a December 2019 interagency statement, summarized in our prior Client Alert, and outlines… Read More
On July 22, 2019, the five federal agencies tasked with the supervision, examination, and enforcement of Bank Secrecy Act and anti-money laundering requirements for banks issued a joint statement clarifying their risk-based approach to BSA/AML examinations. Our alert discusses the key implications of the Statement. Read our client alert.
On December 3, 2018, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Financial Crimes Enforcement Network, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the “Agencies”) issued a joint statement regarding “innovative approaches” to Bank Secrecy Act/anti-money laundering compliance. This is the second joint statement… Read More
There have been two recent virtual currency-related actions worthy of note: (1) the Financial Crimes Enforcement Network (“FinCEN”) announced its first civil enforcement action against a virtual currency exchanger, and (2) the New York Department of Financial Services (“NYDFS”) granted its first license to a Bitcoin exchange. This client alert reviews these recent virtual-currency-related actions and… Read More