Fifth Circuit Rejects OFAC Designation of Tornado Cash Immutable Smart Contracts
Money Laundering Watch News
by Peter D. Hardy, Siana Danch and Kelly A. Lenahan-Pfahlert
14h ago
In a closely watched and complicated case, Van Loon et al. v. Dep’t of the Treasury et al., the U.S. Court of Appeals for the Fifth Circuit ruled that the Office of Foreign Assets Control (“OFAC”) cannot sanction Tornado Cash, “an open-source, crypto-transactions software protocol that facilitates anonymous transactions by obfuscating the origins and destinations ..read more
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FinCEN Alert: Fraud Schemes Using Generative Artificial Intelligence to Circumvent Financial Institution’s Identity Verification, Authentication, and Due Diligence Controls
Money Laundering Watch News
by Kristen E. Larson
2w ago
On November 13, 2024, the Financial Crimes Enforcement Network (FinCEN) issued FIN-2024-Alert004 to help financial institutions identify fraud schemes associated with the use of deepfake media created with generative artificial intelligence (GenAI) in response to increased suspicious activity reporting. “Deepfake media” are a type of synthetic content that use artificial intelligence/machine learning to create realistic ..read more
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FinCEN Issues Proposed Reporting Form for Residential Real Estate Deals
Money Laundering Watch News
by Peter D. Hardy, Richard J. Andreano, Jr., Kaley Schafer and Siana Danch
2w ago
As we previously blogged, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Final Rule, set to go into effect on December 1, 2025, institutes a new Bank Secrecy Act reporting form – the “Real Estate Report” (“Report”) – which imposes a ..read more
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Another Chapter in the Alpine Securities Saga:  District Court Grants Motion to Dismiss Complaint Challenging AML Enforcement Action Against Contractual Partner
Money Laundering Watch News
by Siana Danch
3w ago
In the possible final stage of the Alpine Securities saga (as we blogged about here, here and here), Judge Clark Waddopous of the United States District Court for the District of Utah issued an opinion granting the Securities and Exchange Commission’s (“SEC”) motion to dismiss the amended complaint filed by plaintiff brokerage firm Scottsdale Capital ..read more
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FinCEN Issues Alert on Countering Financing of Hizballah and Terrorist Activities
Money Laundering Watch News
by Kaley Schafer
1M ago
On October 23rd, the Financial Crimes Enforcement Network (“FinCEN”) issued a supplementary alert regarding countering financing of the U.S.-designated foreign terrorist organization Hizballah (the “Alert”). In May 2024, FinCEN published an initial alert that focused on the countering of financing Iran-backed terrorist organizations, including Hizaballah. This Alert focuses solely on Hizballah and indicates that as ..read more
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State Fair Access and Debanking Laws Bring Country’s Political and Cultural Divisions to the Fore: A Podcast
Money Laundering Watch News
by Peter D. Hardy
1M ago
New State Laws Create Tension with Federal AML Requirements An increasing number of states have either enacted or are considering enacting legislation requiring financial institutions to provide persons (both existing customers and prospective customers) who are not ordinarily protected by the federal anti-discrimination statutes with “fair access” to financial services. For example, and as we ..read more
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FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML Program
Money Laundering Watch News
by Peter D. Hardy
1M ago
Card Club Will Pay $900,000 and Undertake AML Program Review The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”).  The Consent Order describes Lake Elsinore, located in California, as a “medium-sized card club” with 22 tables ..read more
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Halkbank Faces Prosecution: U.S. Court of Appeals Denies Sovereign Immunity
Money Laundering Watch News
by Kelly A. Lenahan-Pfahlert
1M ago
On October 22, 2024, the U.S. Court of Appeals for the Second Circuit ruled that Türkiye Halk Bankası A.Ş. (“Halkbank”), owned by the Republic of Turkey, can be prosecuted for allegedly helping Iran evade U.S. sanctions and committing related money laundering and bank fraud. The court rejected Halkbank’s claim of immunity, stating that foreign state-owned ..read more
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Bank Policy Institute Critiques Notice of Proposed Rulemaking to Modernize AML/CFT Programs
Money Laundering Watch News
by Peter D. Hardy and Kaley Schafer
1M ago
The Bank Policy Institute (“BPI”) has issued its comment on the Federal Functional Regulators’ (the OCC, the Board of Governors of the Federal Reserve System, the FDIC, and the National Credit Union Administration) notice of proposed rulemaking (“NPRM”) to modernize financial institutions’ anti-money laundering and countering terrorist financing (“AML/CFT”) programs (“Comment”). The agencies’ NPRM, on ..read more
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FinCEN Withdraws Designation of ABLV Bank as Foreign Financial Institution “Of Primary Money Laundering Concern”
Money Laundering Watch News
by Brian N. Kearney
2M ago
A Gesture Providing Limited Solace to a Now-Defunct Bank Six years ago, in early 2018, we blogged about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (“FinCEN’s”) designation of ABLV Bank, AS (“ABLV”), then the second-largest bank in Latvia, as a foreign financial institution “of primary money laundering concern” pursuant to Section 311 ..read more
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