• Cash Purchases May Complicate Real Estate Buys From Sanctioned Countries
    Heightened Scrutiny of Real Estate Cash Purchases May Complicate Future Buys by Those Tied to Sanctioned Countries On January 13, 2016, the Financial Crimes
  • GTO Issued Against 700 Businesses to Curb Money Laundering in Miami
    FinCEN: Geographic Targeting Order Issued Against ~700 Miami Businesses; Requires Implementation of Elevated Anti-Money Laundering Controls. On April 15, 2015, the U.S.
  • De-banking MSBs: Damned If You Do, Damned If You Don’t?
    On November 10, 2014 the Financial Crimes Enforcement Network (FinCEN) issued a statement encouraging the provision of banking services to Money Services
  • FinCen’s Geographic Targeting Order Hits LA’s Fashion District
    Practitioners who follow the Treasury’s Office of Terrorism and Financial Intelligence (TFI) may have noticed FinCEN’s issuance of a Geographic Targeting Order
  • Smurfing and OFAC
    Originally Published June 10, 2014 How Your Under-$10,000 Transactions Can Actually Raise Your Profile for Investigations by the Feds Whenever a U.S.
  • Foreign Sanctions Evaders and St. Kitts and Nevis
    Originally Published May 21, 2014 Yesterday, the Financial Crimes Enforcement Network ("FinCEN") issued an Advisory "to alert financial institutions that certain foreign individuals are