On March 31, 2016, the Office of the Comptroller of the Currency (“OCC”) issued its much-anticipated white paper on the growing intersection between financial services and technology, or “FinTech.” In this white paper, the OCC outlines steps that it is considering to make the agency more receptive to what it deems “responsible innovation.” From internal … Continue Reading
The Office of the Comptroller of the Currency (“OCC”), the primary federal regulator for most large banks, recently issued a new policy on agency enforcement actions seeking civil money penalties (“CMPs”) against institutions and individuals. There are several key developments that will directly affect institutions and the directors, officers, employees, major shareholders, and vendors associated … Continue Reading
Investment advisers subject to SEC registration would be affected by proposed regulations from the Financial Crimes Enforcement Network. The regulations, proposed in August 2015, would require such investment advisers to create anti-money laundering programs as well as to undertake reporting and recordkeeping responsibilities under the Bank Secrecy Act, including filing suspicious activity reports. For more … Continue Reading
A recent Reed Smith Client Alert discusses a June 2015 speech by Stephanie Brooker, Associate Director for Enforcement at the Financial Crimes Enforcement Network (“FinCEN”). Although Ms. Brooker’s comments were specifically directed at the casino and card club industries, she discussed six “core principles” that have and will continue to guide FinCEN’s BSA/AML enforcement activities … Continue Reading
Introduction Stephanie Booker, Associate Director for Enforcement, Financial Crimes Enforcement Network (“FinCEN”) recently gave a speech at the Nevada Bar Association’s Bank Secrecy Act Conference in Las Vegas. Involved in the conference were the State Bar of Nevada’s Gaming Law Section, the American Gaming Association, and the University of Nevada-Las Vegas’ International Gaming Institute. FinCEN … Continue Reading
On June 15, multiple federal agencies issued a $4.5 million penalty against a local bank that admitted to failing to maintain an effective anti-money laundering program. The coordinated enforcement action by multiple agencies and substantial monetary penalty illustrates the significant risks for anti-money laundering compliance for local financial institutions. The coordinated action was announced by … Continue Reading
On June 3, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a $75 million penalty against a Northern Mariana Islands casino for Bank Secrecy Act violations – the largest-ever FinCEN penalty assessed against a casino. FinCEN’s announcement follows an investigation of the casino, Hong Kong Entertainment (Overseas) Investments, Ltd., d/b/a Tinian Dynasty Hotel & … Continue Reading
