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Guidance issued regarding SAR supporting documentation
  • Katten Muchin Rosenman LLP
  • USA
  • June 22 2007

The Financial Crimes Enforcement Network (FinCEN) has issued guidance providing that financial institutions, including banks, broker-dealers and futures commission merchants, are under an obligation to provide “supporting documentation” related to the filing of any particular suspicious activity report (SAR) when requested to do so by an applicable law enforcement or regulatory agency (including FinCEN

SBA Form 1031: the Whitewater connection
  • Venable LLP
  • USA
  • July 25 2007

Next year will mark the tenth anniversary of a decision noteworthy for sheer political drama, as well as for its unique place in the history of Small Business Administration-backed lending

The long arm (and tight grip) of deposit forfeiture under the USA PATRIOT Act
  • Hogan Lovells
  • USA
  • August 13 2007

The extra-territorial effect of the USA PATRIOT Act is generally limited

Revised Bank Secrecy ActAnti-Money Laundering Examination Manual released
  • Katten Muchin Rosenman LLP
  • USA
  • August 24 2007

On August 24, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, and the Conference of State Bank Supervisors, in collaboration with the Financial Crimes Enforcement Network (collectively, the Banking Agencies) released through the Federal Financial Institutions Examination Council (the FFIEC) a revised Bank Secrecy ActAnti-Money Laundering Examination Manual (the Manual

Final rule issued for correspondent accounts maintained by certain foreign banks
  • Katten Muchin Rosenman LLP
  • USA
  • August 10 2007

The Financial Crimes Enforcement Network (FinCEN) announced yesterday the issuance of a final rule implementing a key provision of Section 312 of the USA PATRIOT Act, clarifying the risk-based procedures that U.S. financial institutions should use in tailoring their enhanced due diligence to assess the risks of some foreign banking relationships

Application of the correspondent account rule to OTC executing dealers
  • Katten Muchin Rosenman LLP
  • USA
  • September 7 2007

The Financial Crimes Enforcement Network (FinCEN) has issued interpretive guidance to clarify the due diligence obligations of executing dealers in over-the-counter foreign exchange and derivatives markets pursuant to prime brokerage arrangements under the correspondent account provisions of the USA PATRIOT Act

Too big to jail?
  • Kelley Drye & Warren LLP
  • USA
  • January 30 2013

Yesterday, Senators Sherrod Brown (D-OH) and Chuck Grassley (R-IA) sent a letter to US Attorney General Eric Holder stating that, among other things

FCPA: the First Circuit court decision defining instrumentality
  • Dorsey & Whitney LLP
  • USA
  • May 18 2014

The Eleventh Circuit Court of Appeals handed down the first decision on the question of who is a foreign official under the Foreign Corrupt Practices

SEC issues alert on Bitcoin investments
  • Thompson Hine LLP
  • Hong Kong, United Kingdom, USA
  • May 20 2014

On May 7, 2014 the Securities and Exchange Commission's Office of Investor Education and Advocacy issued an Investor Alert regarding potential

Lloyds TSB Bank plc forfeits $350 million in settlements with U.S. and New York prosecutors for violations of OFAC sanctions programs against Iran, Sudan and Libya
  • Schulte Roth & Zabel LLP
  • USA
  • February 4 2009

On Jan. 9, 2009, Lloyds TSB Bank Plc (“Lloyds Bank”), a financial institution registered and organized in the United Kingdom and headquartered in London, entered into two separate deferred prosecution agreements with U.S. and New York prosecutors (the “Agreements”) and agreed to forfeit $350 million based on allegations that it had violated the Iranian, Sudanese and Libyan economic sanctions programs administered by the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”