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Schulte Roth & Zabel LLP | USA | 24 Feb 2020

US Government Continues to Penalize Unauthorized Disclosures of Suspicious Activity Reports

On Jan. 13, 2020, a former senior adviser at the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) pleaded guilty in


Carrington Coleman | USA, European Union | 23 Feb 2020

Loss of Privacy Rights When Purchasing Art

In late 2018, the European Union adopted the Fifth Anti-Money Laundering Directive. This Directive updates previous guidance with a focus on


Buckley LLP | USA | 11 Feb 2020

NYDFS to take action against check cashing companies for BSAAML compliance deficiencies

On February 3, NYDFS announced it intends to take enforcement action through an administrative proceeding against several check cashing entities for


Buckley LLP | USA | 8 Jan 2020

FDIC releases November enforcement actions

On December 27, the FDIC announced a list of administrative enforcement actions taken against banks and individuals in November. The 14 orders


Cadwalader Wickersham & Taft LLP | USA | 16 Dec 2019

FinCEN Seeks Nominations for Bank Secrecy Act Advisory Group

FinCEN invited the public to nominate members for the Bank Secrecy Act Advisory Group (the "Group"). The Group serves as adviser to the Treasury on


Paul Hastings LLP | USA | 13 Dec 2019

Financial Regulators Issue Joint Guidance to Snuff Out Reporting Requirement on Legal Hemp-Related Businesses

The requirement under the Bank Secrecy Act (“BSA”) that banks file Suspicious Activity Reports (“SARs”) concerning their customers solely because


Morgan Lewis | USA | 12 Dec 2019

Interagency Statement on Hemp-Related Business: No Comfort for Cannabis

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and


Eversheds Sutherland (US) LLP | USA | 12 Dec 2019

Federal agencies clarify SAR filing requirements for financial services provided to hemp-related businesses

On December 3, 2019, four federal agencies, in consultation with state banking regulators, clarified the legal status of hemp growth and production


White & Case LLP | USA | 10 Dec 2019

Federal Banking Agencies Open a Pathway to the Provision of Banking Services to Hemp-Related Businesses

On December 3, 2019, in a rare public statement regarding the provision of banking services to cannabis- or hemp-related businesses, the Federal


Buckley LLP | USA | 6 Dec 2019

FinCEN report: SARs help prevent elder financial exploitation

On December 4, FinCEN announced the release of a Financial Trend Analysis titled, “Elders Face Increased Financial Threat from Domestic and Foreign

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