FinCEN Proposes Expansion of CIP Requirements to Investment Advisers
QuickBridge Blog
by Evan Abrams, Jack Hayes and Sandra Hanna
6M ago
On May 21, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly published a notice of proposed rulemaking (NPRM) that would require investment advisers registered under the Investment Advisers Act of 1940 (RIAs) and exempt reporting advisers (ERAs) (collectively, “investment advisers”) to maintain customer identification programs (CIPs). Many types of U.S. financial institutions are required to maintain CIPs as part of their anti-money laundering (AML) compliance program and must, as part of the CIP r ..read more
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President Signs Expansive Sanctions Bill Into Law; Doubling of Limitations Period for IEEPA Violations Likely to Have Major Impact
QuickBridge Blog
by Quentin Johnson, Ryan Pereira, Peter Jeydel, Evan Abrams, Meredith Rathbone, Brian Fleming, Byron Maniatis, Wendy Wysong, Ali Burney and Sean Gallagher
7M ago
On April 24, 2024, President Biden signed HR 815, “Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes,” into law (the “National Security Supplemental” or the “NSS”). The National Security Supplemental appropriates funds to provide security assistance to Ukraine, Israel, and US partners in the Indo-Pacific and humanitarian aid for Gaza. Alongside the appropriations measures, the National Security Supplemental includes the “21st Century Peace through Strength Act”, a collection of fourteen sanctions, export controls, and related reg ..read more
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UK NECC Publishes Amber Alert on Sanctions Evasion in the Art Storage Sector
QuickBridge Blog
by Alexandra Melia and Elliot Letts
10M ago
The UK’s National Economic Crime Centre (“NECC”) recently issued an amber alert concerning the sanctions evasion, money laundering, and trafficking in cultural property risks presented to UK industries linked to artwork storage facilities and the art storage sector (the “Amber Alert”).  The Amber Alert highlights that criminals are finding ways to utilize the art market to conduct illicit activity and includes case studies and key indicators that those operating within the art storage sector can use to detect such activity.  This development underscores the UK government’s continued ..read more
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Potential new SAR-like Reporting Requirements for Certain U.S. Real Estate Transactions
QuickBridge Blog
by Jack Hayes and Jim Carolan
10M ago
On February 8, 2024, the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (2024 NPRM) about Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) regulations concerning persons involved in residential real estate closings and settlements. To promote U.S. AML/CFT objectives, the NPRM proposes a system of streamlined Suspicious Activity Reports (SARs) for certain U.S. real estate transactions. The NPRM does yet not have the force and effect of law, and FinCEN has requested public comments to be submitted ..read more
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FinCEN Proposed Rule Targets Digital Asset Mixers
QuickBridge Blog
by Evan Abrams, Sophia Breggia and Dave Stetson
1y ago
On October 19, 2023, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rulemaking (NPRM) that would implement new recordkeeping and reporting requirements on domestic financial institutions and domestic financial agencies, related to transactions that they know, suspect, or have reason to suspect involve convertible virtual currency (CVC) mixing within or involving a non-U.S. jurisdiction.  FinCEN issued the NPRM pursuant to Section 311 of the USA PATRIOT Act, which provides the Secretary of the Treasury (the “S ..read more
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Critical Tornado Cash Developments Have Significant Implications for DeFi AML and Sanctions Compliance
QuickBridge Blog
by Evan Abrams, Dave Stetson and Jack Hayes
1y ago
After months of anticipation, a federal judge has finally ruled in the closely watched case of Joseph Van Loon, et al. v. Department of Treasury, et al.  This important case addressed challenges to the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) decision to impose sanctions on Tornado Cash as a Specially Designated National and Blocked Person (SDN).  The judge granted summary judgement in favor of OFAC, finding it had sufficient legal authority to designate Tornado Cash, and denied summary judgement on the plaintiffs’ claims.  Shortly after that rulin ..read more
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Risk Assessment Offers Treasury’s Most Extensive Comments to Date on DeFi Regulation
QuickBridge Blog
by Evan Abrams
1y ago
The Department of the Treasury’s recently issued Illicit Finance Risk Assessment of Decentralized Finance is principally intended to provide insight on how illicit actors are abusing decentralized finance (DeFi) services, as well as anti-money laundering (AML) and countering the financing of terrorism (CFT) vulnerabilities unique to DeFi.  However, the report also contains critical insight on how Treasury, and, presumably, the Financial Crimes Enforcement Network (FinCEN) within Treasury, view the applicability of existing US AML/CFT regulations, issued pursuant to the Bank Secrecy Act (B ..read more
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In Unprecedented Action FinCEN Identifies Virtual Currency Exchange as Primary Money Laundering Concern
QuickBridge Blog
by Evan Abrams, Dave Stetson, Brian Fleming and Jack Hayes
2y ago
On January 18, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an order identifying the virtual currency exchange Bitzlato Limited (Bitzlato) as a “primary money laundering concern” in connection with Russian illicit finance.  The order, which is the first of its kind, was issued pursuant to Section 9714(a) of the Combating Russian Money Laundering Act.  Section 9714(a) is a relatively new provision that authorizes the Secretary of the Treasury to identify a financial institution operating outside the United States as a “primary money la ..read more
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Proposed Rule Lays Out Who Will Have Access to New Corporate Beneficial Ownership Information
QuickBridge Blog
by Evan Abrams and Dave Stetson
2y ago
On December 16, FinCEN issued a notice of proposed rulemaking (NPRM) entitled “Beneficial Ownership Information Access and Safeguards, and Use of FinCEN Identifiers for Entities.”  The NPRM is intended to implement the Corporate Transparency Act (CTA) and, in particular, to govern which entities may access corporate beneficial ownership information (BOI) that certain entities will soon be required to report to FinCEN under the CTA.  Steptoe previously summarized FinCEN’s final rule on BOI reporting here. What Happened The new NPRM outlines the specific situations in which FinCEN will ..read more
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DFS’s First Enforcement Action Against a Blockchain Company: Lessons Learned
QuickBridge Blog
by Jason Weinstein, Dave Stetson, Evan Abrams and Ryan Pereira
2y ago
On August 1, Robinhood Crypto, LLC (RHC) entered a consent order with the New York State Department of Financial Services (DFS) requiring RHC to pay a $30 million fine for violating (1) New York’s virtual currency regulatory regime known as the BitLicense, (2) a Supervisory Agreement entered with DFS as a condition of its BitLicense, (3) anti-money laundering (AML) requirements applicable to money transmitters, and (4) other requirements related to transaction monitoring, filtering, and cybersecurity.  The consent order, which is DFS’s first enforcement action under the BitLicense regime ..read more
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