In 2020, we wrote about the increased regulatory attention on financial institutions’ obligations to detect and respond to human trafficking. In 2021, we wrote about how anti-human trafficking programs fit squarely in banks’ risk management and ESG platforms. As 2022 comes to a close, we add to these alerts an area of emerging potential bank liability – civil actions alleging failure to detect and respond to human trafficking.
A few weeks ago, two sex trafficking survivors filed lawsuits against two international financial institutions including claims under the ...
On October 15, 2020, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) released its Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity (Supplemental Advisory). The last time FinCEN provided guidance on identifying trafficking in anti-money laundering (AML) processes was in Guidance on Recognizing Activity that May be Associated with Human Smuggling and Human Trafficking – Financial Red Flags on September 11, 2014. The evolving tactics of human traffickers and behaviors of victims required ...
By John Han and Katherine Lamberth. President Trump piqued the interest of participants in and observers of the marijuana industry when he stated in early June that he would “probably” support recently proposed bipartisan legislation aimed at removing the federal prohibition on certain marijuana-related activity. President Trump’s statement is significant because it:
- indicates presidential support for the bill, which other legislative attempts at reforming federal marijuana laws have generally lacked, and
- signals a shift from the strict enforcement position taken ...
By Neil Bloomfield and Nathan White. After the Panama Papers exposed efforts by wealthy individuals and government officials to hide funds offshore, government authorities around the world have responded with new legislation, regulations and enforcement actions that are beginning to reshape the landscape for anti-money laundering (AML) and Bank Secrecy Act (BSA) violations. This post will be the first in a series of updates as the world begins to redefine these issues and what that means for companies that need to comply with the new standards.
In some areas, the ...
About MVA White Collar Defense, Investigations, and Regulatory Advice Blog
As government authorities around the world conduct overlapping investigations and bring parallel proceedings in evolving regulatory environments, companies face challenging regulatory and criminal enforcement dynamics. We help keep our clients up to date in these fast-moving areas and to serve as a thought leader.
MVA White Collar Defense, Investigations, and Regulatory Advice Blog Updates
- Federal Reserve Board Issues Denial to Custodia Bank
- States Look to Impose Financing Disclosure Requirements on Commercial Loans and the CFPB Considers Potential TILA Preemption Considerations
- Banks – What Should You Know? Civil Liability for Failure to Detect Human Trafficking
- Client Alert: Beneficial Ownership Reporting at the Federal Level effective January 1, 2024