On March 30, 3023, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis focusing on business email compromise (BEC) trends and patterns in the real estate sector (referred to as “RE BEC”). The report is required under Section 6206 of the Anti-Money Laundering Act of 2020 (AMLA). This section of AMLA requires FinCEN
FinCEN
Privacy, Cybersecurity and Access to Beneficial Ownership Information: FinCEN Issues Notice of Proposed Regulations Under the Corporate Transparency Act
A Deep Dive Into FinCEN’s Latest Proposals Under the CTA
On December 16, the Financial Crimes Enforcement Network (“FinCEN”) issued a 54-page notice of proposed rulemaking (“NPRM”) regarding access by authorized recipients to beneficial ownership information (“BOI”) that will be reported to FinCEN under the Corporate Transparency Act (“CTA”). The CTA requires covered entities –…
European Court Puts the Brakes on AML Directive: Public Access to Beneficial Ownership Database Violates European Privacy Laws
Ruling Could Influence FinCEN in Forthcoming Regulations Under the CTA
On November 22nd, an appeals court in Luxembourg issued a decision that highlights the tensions between anti-money laundering (“AML”) goals and privacy concerns, and could impact impending beneficial ownership regulations to be issued under the U.S. Corporate Transparency Act (“CTA”). Specifically, the appeals court decided…
FinCEN Reports Staggering Increase in Reported Ransomware Attacks
The “Highlights” — To Russia, With Crypto
The Financial Crimes Enforcement Network (“FinCEN”) issued on November 1 a Financial Trend Analysis regarding ransomware-related Bank Secrecy Act (“BSA”) filings during the second half of 2021 (the “Report”). This publication follows up on a similar ransomware trend analysis issued by FinCEN regarding the first half of 2021…
OFAC Targets Virtual Currency Exchange for Allegedly Facilitating Ransomware Attack
OFAC Updates Advisory on Enforcement Risks Relating to Agreeing to Pay Ransomware
First Post in a Two-Part Series on Recent OFAC Designations
On September 21, 2021 OFAC issued its first sanctions designation against a virtual currency exchange by designating the virtual currency exchange, SUEX OTC, S.R.O. (SUEX) “for its part in facilitating financial transactions for
…
FinCEN Director Blanco Addresses “Cyber Hygiene”
Remarks Focus on Account Takeovers, BEC Schemes, Beneficial Ownership, Technological Innovation and SARs
FinCEN Director Kenneth A. Blanco delivered prepared remarks on September 24 at the 2019 Federal Identity (FedID) Forum and Exposition in Tampa, Florida.
Director Blanco summarized the topics of his remarks by stating the following:
- First, I would like to tell you
…