Category Archives: Money Laundering

New York Federal Prosecutors Indict Defendant in Connection with NFT Insider-Trading Scheme

Federal prosecutors from the Southern District of New York recently charged Nathan Chastain with wire fraud and money laundering in connection with a purported scheme to illegally profit from sales and purchases of Non-Fungible Tokens (“NFTs”).[1]  This landmark criminal case marks the first time federal prosecutors have pursued criminal action to police insider trading in the NFT marketplace.

Chastain is a former employee of Ozone Networks,… More

NY Department of Financial Services Slaps $30 Million Fine on Robinhood’s Crypto Platform for Lax Anti-Money Laundering Controls

On August 1, 2022, the New York Department of Financial Services (“DFS” or the “Department”) secured its first enforcement win against a cryptocurrency platform, Robinhood’s crypto trading arm Robinhood Crypto, LLC.

Robinhood Crypto is a wholly-owned subsidiary of Robinhood Markets, Inc. (RHM).  RHM allows users to trade stocks on a commission-free basis through its broker-dealer subsidiary, Robinhood Financial, LLC (RHF).  Robinhood Crypto allows RHF customers to trade cryptocurrencies using customers’ U.S.… More

Criminal Tax Violations: 2022 Enforcement Trends

This is the third post in this year’s series examining important trends in white collar law and investigations. Our previous post discussed trends in anti-corruption. Up next: State AG enforcement trends.

  • While the volume of IRS enforcement actions has waned, it may soon increase.
  • Even at current relatively low audit and investigation levels, the IRS remains aggressive in the cases it does pursue.…
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Anti-Corruption in 2022: A Look Ahead

This is the second post in this year’s series examining important trends and new development in white collar law and investigations.  Our previous post discussed health care enforcement. Up next: trends in tax enforcement.

As the Biden administration moves into its second year, we anticipate both an increase in U.S. anti-corruption enforcement activity, and a broader, whole-of-government approach that seeks to encourage and reward international partners for their efforts in combatting corruption. … More

Sanctions/Export Controls Trends in 2021

This is the second in our First 100 Days series examining important trends in white collar law and investigations in the early days of the Biden administration. Our previous entry discussed SEC enforcement. Up next, anti-corruption trends.

The recent change in administrations has generated much discussion about what to expect in the worlds of export controls and sanctions in 2021.  In general,… More

U.S. Senate Considering Update to Federal Anti-Money Laundering System

A bipartisan group of Senators, with the support of the American Bankers Association, recently introduced bill S.2563, known as the ILLICIT Cash Act.  The acronym “ILLICIT” stands for “Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal Activity in Shell Holdings.”  As that name suggests, the bill’s primary purposes are to close loopholes involving shell companies, improve information collection, and encourage communication between financial institutions and law enforcement. … More

To Avoid Expensive Trouble with Regulators, Banks Should Invest in a BSA Officer with Substantial Authority and Staff Support

While it is often said that “you have to spend money to make money,” it is less often said, but equally true, that you have to spend money to avoid spending a whole lot more money later.  For a bank, investing in a strong Bank Secrecy Act (“BSA”) Officer with an ample anti-money laundering (“AML”) compliance staff could help avoid significant expense down the road.

The BSA,… More