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On May 19, Alessio Evangelista, the Associate Director of the Enforcement and Compliance Division of FinCEN, presented at the Chainalaysis Links Conference on the topic of “Intersection of Cryptocurrencies and National Security.”  Evangelista stated that crypto firms “have the same obligations as all other financial institutions to ensure that their new offerings can leverage innovations while still protecting consumers, reducing cybercrime, combating illicit financial activity, and ensuring their platforms are not used to harm our national security.” He also stressed that the agency believes that innovation goes hand in hand with regulation, rather than being at odds with each other.  …
Continue Reading FinCEN Highlights Responsible Crypto Innovation, Warns Service Providers

On March 17, the OCC and FinCEN issued civil monetary penalties against a federal savings bank for “willfully” failing to meet minimum compliance program requirements and shoddy suspicious transaction reporting. The consent orders read like a veritable “how not to” for reviewing anti-money laundering alerts.
Continue Reading OCC and FinCEN Issue $200 Million in Penalties for BSA-AML Violations

On February 4, the Department of the Treasury published a study on the facilitation of money laundering and terrorist financing through the art trade.  Among other considerations, the report discussed the risks of financial crimes in connection with NFTs.  (See a previous post on NFTs from our sister blog here and a recent podcast here).  The study found that the high-value art market has certain inherent qualities that make it potentially vulnerable to a range of financial crimes – as we noted above.  NFT purchasers, marketplaces, issuers, and other intermediaries in NFT transactions should be aware of the Treasury Departments’ interest in regulation and the potential for abuse through NFT transactions. This Treasury Department report is the latest in a series of studies and reports by federal regulatory agencies that aim to warn investors about the potential for abuse. …
Continue Reading Treasury’s Study Discusses Financial Crimes and NFTs

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) and the Financial Crimes Enforcement Network (“FinCEN”) issued civil monetary penalties against a Texas community bank for violations of the Bank Secrecy Act (“BSA”).  The consent orders read like a veritable “how not to” for reviewing anti-money laundering alerts.
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Continue Reading OCC and FinCEN Issue $9 Million in Penalties for BSA-AML Violations