Central Bank Guidance to UAE Financial Institutions Banking Cash-Intensive Businesses

The Central Bank of the UAE (“CBUAE”) has issued new guidance (the “Guidance”) to UAE financial institutions providing services to cash-intensive businesses. The specific characteristics of cash—anonymity, interchangeability, and transportability—make it an attractive medium for illicit actors seeking to obfuscate the proceeds of crime or the funding of terrorism.  Unlike other monetary instruments, such as …
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Anti-Money Laundering Act Update: One Year In

The National Defense Authorization Act for Fiscal Year 2021 became law early in 2021, after a congressional override of then-President Trump’s veto.  Division F of the NDAA consists of the Anti-Money Laundering Act of 2020 (“AMLA”).  The AMLA expands numerous Bank Secrecy Act (“BSA”) requirements, and FinCEN has continued to issue guidance, reports, and proposed …
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The Biden Administration Announces Strategy to Combat Global Corruption

On December 6, 2021, the White House (the “WH”) released the first United States Strategy on Countering Corruption (the “Strategy”) that sets the Biden-Harris Administration’s goals to tackle international corruption. Much of the Strategy remains currently aspirational and requires additional legislative and regulatory action to implement. Still, it signals the direction the Administration is looking …
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OFAC Releases Sanctions Compliance Guidance for the Virtual Currency Industry

The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury recently published sanctions compliance guidance for the virtual currency industry (the Guidance).  The move was long anticipated, given the rapid industry growth and limited regulator guidance in this space.  The Guidance provides an overview of OFAC sanctions requirements and procedures, including …
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The Treasury 2021 Sanctions Review is Complete: What Next?

On October 18, 2021, the U.S. Department of the Treasury (“Treasury”) released the findings from its review of the economic sanctions administered and enforced by its Office of Foreign Assets Control (“OFAC”). During the review, Treasury met with individuals representing hundreds of sanctions stakeholders, including Members of Congress and their staffs, the private sector, foreign …
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UAE’s New Executive Office of AML/CFT and Dubai’s New Specialized Money Laundering Court

On August 22, 2021, at the directive of His Highness Sheikh Mohammed bin Rashid al Maktoum, Vice President and Prime Minister of the UAE and Ruler of Dubai, Dubai Courts announced the establishment of a specialized new court that will focus on combating money laundering.  The announcement comes just months after the UAE Cabinet approved …
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OFAC Issues Updated Ransomware Advisory and Designates Virtual Currency Exchange

On September 21, 2021, the United States Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued an Updated Advisory on Potential Sanctions Risks for Facilitating Ransomware Payments (the “Updated Advisory”) superseding its earlier October 1, 2020 guidance on ransomware attacks and, for the first time, added a virtual currency exchange to the Specially …
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New Central Bank Guidance for UAE Financial Institutions on Suspicious Activity/Transaction Reporting

On June 7, 2021, the UAE Central Bank issued new guidance requiring all UAE financial institutions to file suspicious activity reports (SARs) or suspicious transaction reports (STRs) with the UAE’s Financial Intelligence Unit (FIU) using the goAML portal within 35 calendar days of detection of any conduct that they reasonably suspect may be linked to …
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Anti-Money Laundering Act Update: Six Months In

The National Defense Authorization Act for Fiscal Year 2021 (“NDAA”) became law earlier this year, after a congressional override of then-President Trump’s veto.  Division F of the NDAA consists of the Anti-Money Laundering Act of 2020 (“AMLA”).  The AMLA expands numerous Bank Secrecy Act (“BSA”) requirements, and FinCEN has been active in the first sixth …
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Anti-Money Laundering Act Update: Six Months In

The National Defense Authorization Act for Fiscal Year 2021 (“NDAA”) became law earlier this year, after a congressional override of then-President Trump’s veto.  Division F of the NDAA consists of the Anti-Money Laundering Act of 2020 (“AMLA”).  The AMLA expands numerous Bank Secrecy Act (“BSA”) requirements, and FinCEN has been active in the first sixth …
Continue reading Anti-Money Laundering Act Update: Six Months In