Is there help on the Way for the De-risked?

March 2021

Rising compliance costs, hard to understand corporate client structures, fines and penalties, a shift from corporate responsibility to individual liability, and reputational concerns have led many US Financial Institutions (“FI”) to de-risk or end customer relationships as along with the

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New Criminal Offenses related to Foreign Political Figures and Money Laundering Entities

February 2021

Regarding assets belonging to Senior Foreign Officials, Section 6313 of the AML Act of 2020 prohibits the concealment of the source of those assets in monetary transactions or involving Institutions of primary Money Laundering concern as two new criminal offenses. 

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Treasury Attachés, Foreign Financial Intelligence Unit Liaisons and Foreign Financial Institutions

February 2021

The AML Act of 2020 includes the creation of  “Treasury Attachés” (SEC. 6106, appointed by the US Treasury Department) and the “Foreign Financial Intelligence Unit Liaisons” (SEC. 6108, appointed by FinCEN) to be stationed abroad.   The Treasury Attachés will: Assist

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Foreign Bank and the New Longer Arm of the US Treasury and DOJ

February 2020

Before passage of the AML ACT of 2020 (the “ACT”), The US Department of the Treasury, and the US Justice Department (DOJ) had US legal authority to subpoena foreign banks with US correspondent accounts for related US records including records

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FinCEN provides further SAR Clarity

February 2021

On January 19, 2021, FinCEN issued Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations.  The answers to seven questions were provided by FinCEN in response to recent Bank Secrecy Act Advisory Group (BSAAG) recommendations,

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¿Estarán las Instituciones Financieras Preparadas para la Propuesta de Reglamentación del “Travel Rule”?

February 2021

El “Travel Rule” es una regla de la Ley de Secreto Bancario (“BSA”) regla [31 CFR 103.33(g)] y requiere que todas las instituciones financieras transmitan cierta información a la siguiente institución financiera, en ciertas transferencias de fondos que involucren a

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FinCEN provides a Section 314(b) welcomed clarification

January 2021

Section 314(b) of the USA PATRIOT Act (Sec 314) was drafted by Congress in 2001 to allow financial institutions to work with law enforcement agencies and with each other to support the common goal of deterring money laundering and terrorist

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Get Started with Reducing your 2020 Tax bill now

December 2020

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The Anti-Money Laundering Act of 2020 may be a Game-Changer for Compliance Professionals

December 2020

On December 2, 2020, the ‘‘William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021’’ was passed by the U.S. House of Representatives.  The Act includes DIVISION F (ANTI-MONEY LAUNDERING).  This Division is cited as the ‘‘Anti-Money Laundering

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IRS Agents Use Methods of Proof

December 2020

The IRS has tools inside of its Internal Revenue Manual (“IRM”) available to its agents for determining a Taxpayer’s taxable income as well as documenting its adjustments and corrections through what it calls “Methods of Proof”.  The IRM describes seven

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A Forensic Accountant digs beneath the surface and finds what is missing

December 2020

The decision to hire a Forensic Accountant can be a gamble. Not all possess critical characteristics such as being able to see beyond what is immediately in front of them utilizing a panoramic approach.  Traditionally, a CPA looks at historical

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