Tag Archives: FinCen

Treasury Secretary Suggests Greener Pastures for Marijuana Banking

On Tuesday February 6, 2018, U.S. Treasury Secretary Steven Mnuchin, in a speech before the House Financial Services Committee, offered some insights into how the Treasury Department may respond the growing area of marijuana banking. As we reported in a January 5th client alert, the Justice Department rescinded Obama-era policies that provided guidance to federal … Continue Reading

2015 FinCEN Enforcement Trends

To read a review of FinCEN’s enforcement efforts in 2015 and 2014 , which reveal a marked trend away from its longstanding focus on depository institutions and toward otherwise unregulated financial institutions, as well as an increased focus on pursuing penalties against individuals, view the Reed Smith client alert here.… Continue Reading

Hastert Reaches Plea Deal in Anti-Money Laundering Case – Guilty Plea Expected

As I reported in a June 2, 2015 client alert, on May 28, 2015, Dennis Hastert, former Speaker of the U.S. House of Representatives, was indicted by a federal grand jury in the Northern District of Illinois. Mr. Hastert, a former high school teacher and football coach, was charged with making a “materially false, fictitious, … Continue Reading

FinCEN Proposes AML Regulations for Investment Advisers

In August 2015, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed regulations that would require investment advisers subject to SEC registration to establish anti-money laundering (AML) programs.1 The proposal also adds such investment advisers to the definition of “financial institutions” under the Bank Secrecy Act (BSA), which consequently requires them to report … Continue Reading

FinCEN Speech Outlines “Core Principles” on Enforcement

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

Legalized Marijuana Guidance Leaves Some Banks Dazed and Confused

Last week, the Financial Crimes Enforcement Network (“FinCEN”) issued new guidance in response to several states passing legislation to legalize marijuana for medical purposes, and in some states, for recreational purposes as well. This has left many financial institutions scratching their heads as to how to comply with the Bank Secrecy Act (“BSA”), which requires … Continue Reading
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