On April 18, 2019, the Financial Crimes Enforcement Network of the U.S. Department of the Treasury announced the assessment of a civil money penalty against Eric Powers for willfully violating the registration, program and reporting requirements of the Bank Secrecy Act and its implementing regulations. Between December 2012 and September 2014, Mr. Powers acted as
FinCEN
The New AML Rules: Implications for Private Fund Managers
By Brad L. Caswell, Marc E. Elovitz, Melissa G.R. Goldstein, Seetha Ramachandran, Betty Santangelo & Gary Stein on
Posted in FinCEN
On Aug. 25, 2015, the Financial Crimes Enforcement Network (“FinCEN”) issued for public comment a proposed rule (the “Proposed Rule”) requiring investment advisers registered with the SEC (“RIAs”) to establish anti-money laundering (“AML”) programs and report suspicious activity to FinCEN pursuant to the Bank Secrecy Act (“BSA”).
The long-anticipated Proposed Rule arrives nearly seven years…
Federal and State Regulators Target Compliance Officers — Part II
By Betty Santangelo, Gary Stein, Jennifer M. Opheim, Seetha Ramachandran & Melissa G.R. Goldstein on
Posted in FinCEN
On Dec. 18, 2014, the Financial Crimes Enforcement Network issued a first-of-its-kind $1-million assessment against the former chief compliance officer and senior vice president of government affairs at MoneyGram International Inc. Separately, on Dec. 22, 2014, Bank Leumi USA and Bank Leumi Le-Israel, B.M. entered into a consent order with the New York State Department…
New Anti-Money Laundering Rules for Registered Investment Advisers Proposed by FinCEN
By Schulte Roth & Zabel on
Posted in FinCEN
Today, Aug. 25, 2015, the Financial Crimes Enforcement Network (“FinCEN”), a bureau of the U.S. Department of the Treasury, issued for public comment a proposed rule requiring investment advisers registered with the SEC (“RIAs”) to establish anti-money laundering (“AML”) programs and report suspicious activity to FinCEN pursuant to the Bank Secrecy Act (“BSA”) (the “Proposed Rule”).
Continue Reading New Anti-Money Laundering Rules for Registered Investment Advisers Proposed by FinCEN
Federal and State Regulators Target Compliance Officers — Part I
By Betty Santangelo, Gary Stein, Jennifer M. Opheim, Seetha Ramachandran & Melissa G.R. Goldstein on
Posted in FinCEN
On Dec. 18, 2014, the Financial Crimes Enforcement Network (“FinCEN”) issued a first-of-its-kind $1-million assessment against the former chief compliance officer and senior vice president of government affairs at MoneyGram International Inc. FinCEN determined that the CCO “willfully violated” the requirements to: (1) “implement and maintain an effective anti-money laundering program;” and (2) “report suspicious…
FinCEN’s ANPRM on Customer Due Diligence for Financial Institutions
By Betty Santangelo on
Posted in FinCEN
On March 5, 2012, FinCEN issued an advanced notice of proposed rulemaking (“ANPRM”) requesting input from various industries on customer due diligence (“CDD”) requirements for financial institutions. Financial institutions that would be covered by this CDD rule would include banks, broker-dealers, mutual funds, futures commission merchants and introducing brokers in commodities. In addition, other industries…