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Articles by Dane N. Sowers
FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing | JD Supra
On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM)1 taking aim at convertible virtual currency (CVC) mixing transactions, utilizing for the first time its power under the Patriot Act to implement a “special measure” for financial institutions for matters related to a “primary money laundering concern”2 (Proposed Rule).
DOJ sweetens the deal for companies that “come forward, cooperate, and remediate” | JD Supra
On January 17, 2023, Assistant Attorney General Kenneth A.
The DOJ’s new guidance on corporate criminal enforcement - and what it means for your business | JD Supra
On September 15, 2022, Department of Justice (DOJ) Deputy Attorney General (Deputy AG) Lisa Monaco announced new guidance for the DOJ’s corporate enforcement policies,1 which is memorialized in the Memorandum on Further Revisions to Corporate Criminal Enforcement Policies Following Discussions with Corporate Crime Advisory Group (Memorandum).2 As outlined in Deputy AG Monaco’s speech, the Memorandum expounds upon the three changes she announced in her October 2021 speech, as well as two...
California and New Jersey setting the pace in nationwide race to write the rules for crypto | JD Supra
The race to establish a national framework for the regulation of digital assets is heating up, with both California and New Jersey taking action this past week.
Financial Crime Horizon Scanner: 2022 - Q1 (UK) | JD Supra
Our quarterly Financial Crime Horizon Scanner for the UK summarizes key financial crime related legal and regulatory changes expected over the next 2 years and provides electronic links to key resources. We hope that you find the booklet of use to you and your teams. Please see full Publication below for more information. Download PDF
Treasury study expresses concern about money laundering risks associated with NFTs | JD Supra
On February 4, 2022, the US Department of the Treasury (the Treasury) released the “Study of the Facilitation of Money Laundering and Terror Finance through the Trade in Works of Art” (the Report).1 The Report examines the anti-money laundering/combating the financing of terrorism (AML/CFT) risks associated with the antiquities and art markets.
Stymied fraud prosecutions could force DOJ prosecutors to reevaluate their strategy | JD Supra
On January 27, 2022, the United States Court of Appeals for the Second Circuit issued a decision in United States v.
The Biden Administration’s New Attack on Corruption: What Businesses Need to Know
Though broad in scope, the Biden Administration’s plan to counter domestic and international corruption follows four primary lines of effort. A series of related proposals for rule-making conclude their comment period in February. Business leaders have the opportunity to respond to both in advance of enforcement.
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