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Category Archives: Anti-Money Laundering

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Commerzbank Fined $1.45 Billion For Sanctions And Money Laundering Violations

Posted in Anti-Money Laundering, Compliance, Economic Sanctions, National Security
Commerzbank AG, the second-largest bank in Germany, is the latest in a series of foreign banks to be fined hundreds of millions of dollars for violations of U.S. sanctions and anti-money laundering (AML) laws. Commerzbank and its New York branch have agreed to pay fines and forfeitures totaling $1.45 billion, including $259 million imposed by… Continue Reading

Identifying UBOs: The Conflict Between FINCEN and OFAC

Posted in Anti-Money Laundering, Compliance, Economic Sanctions
Identifying who the hidden owners of an entity may be is a key step in combatting money laundering and terrorist financing and complying with U.S. sanctionslaws. For banks in particular, this means identifying the ultimate beneficial owners (UBOs) of customers who are legal entities. Typically, banks will try to identify everyone holding some specified percentage… Continue Reading

Foreign Exchange Trading: The Need For Internal Controls

Posted in Anti-Money Laundering, Economic Sanctions
On November 12, 2013, the Commodity Futures Trading Commission (CFTC) announced that it had imposed fines totaling $1.4 billion on five major international banks in connection with the alleged manipulation of foreign exchange benchmark rates. In each case, the CFTC asserted that individual traders within the banks had colluded to move benchmark foreign exchange rates,… Continue Reading

FinCEN Issues Guidance on Updated FATF List of High-Risk and Non-Cooperative Jurisdictions

Posted in Anti-Money Laundering
On November 12, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released an advisory of the Financial Action Task Force (FATF), which identified jurisdictions with anti-money laundering (AML) and combatting the financing of terrorism (CFT) deficiencies.  FATF, an inter-governmental policy-making body that develops and promotes policies to combat money laundering and terrorist financing,… Continue Reading

FinCEN Clarifies that Anti-Money Laundering Rules Apply to Virtual Currencies

Posted in Anti-Money Laundering
Companies involved in virtual currency business must consider anti-money laundering compliance.  Dealing in virtual currencies, like Bitcoin, could trigger obligations under the Bank Secrecy Act (BSA), such as the duty to report suspicious activity. This week, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) determined that, in two cases, businesses dealing in virtual… Continue Reading
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