Tag Archives: “Bank Secrecy Act”

Is a Hurry-Up Wire Transfer of $3 Billion on Behalf of a Malaysian Government Fund to a Little-Known Private Bank Suspicious? Apparently Goldman Sachs Didn’t Think So.

Multiple news sources (for example, here and here) are reporting that the U.S. government is conducting an investigation into whether Goldman Sachs violated the so-called Bank Secrecy Act (real and less-Orwellian name: Currency and Foreign Transactions Reporting Act of 1970) by conducting a highly suspicious wire transfer and failing to file a Suspicious Activity Report … Continue Reading

U.S. Treasury Seeks to Stanch Flow of Proceeds of Corruption and Other Crimes Into Manhattan and Miami Luxury Real Estate

On January 13, 2016, the U.S. Treasury’s financial intelligence unit, known as the Financial Crimes Enforcement Network (FinCEN), announced the issuance of geographic targeting orders (GTOs) to certain unnamed real estate title insurance companies. These orders will require the subject title insurance company to find out who the true flesh-and-blood purchaser (“beneficial owner”) is when … Continue Reading

FinCEN Imposes Significant Fines In a Warning to Adhere to Due Diligence Requirements

In its recent decision to impose $20 million in sanctions upon Oppenheimer and Co. for the company’s failure to maintain internal controls to promote enforcement of the Bank Secrecy Act (BSA), FinCEN revealed the emphasis it places on financial institutions that may be inadvertently permitting unlawful transactions by independent bad actors. Although the financial institution … Continue Reading

FinCEN Strikes at Virtual Currency Anonymity, Rules that Virtual Currency Converter is a Money Services Business Under Bank Secrecy Act

On October 27, 2014, FinCEN ruled in response to a Request for Administrative Ruling that a company that converts traditional currencies into Bitcoin to facilitate payments must comply with regulations that govern Money Services Businesses under the Bank Secrecy Act. The company at issue operates by receiving payment from a buyer or debtor in “currency … Continue Reading

FinCEN Fines TD Bank for Failing to Report Nearly $1 Billion in Suspicious Transactions Related to Florida Ponzi Scheme

The Financial Crimes Enforcement Network (FinCEN) announced the assessment of a $37.5 million civil money penalty against TD Bank, N.A. for failure to file suspicious activity reports related to the massive Ponzi scheme orchestrated by Florida attorney Scott Rothstein. The Office of the Comptroller of the Currency also announced the assessment of a concurrent $37.5 … Continue Reading
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