Civil Money Penalties and Criminal Prosecutions Against Unregistered Money Transmitters

On March 2, 2011, the Financial Crimes Enforcement Network (“FinCEN”) announced an assessment of Civil Money Penalties totaling $40,000 against brothers Omar Abukar Sufi and Mohamed Abukar Sufi (the “Sufi Brothers”), for non-compliance with the Bank Secrecy Act (“BSA”) money transmitter registration requirements (the “Announcement”). The Sufi Brothers, doing business as Halal Depot of Wyoming, […]


FinCEN’s New Chapter X Becomes Effective

Today, the Financial Crimes Enforcement Network (“FinCEN”) announced that it transferred the current Bank Secrecy Act regulations (“BSA Regulations”) to a new chapter in the Code of Federal Regulations (“CFR”) (the “Announcement”).  FinCEN has restructured the BSA Regulations so that they can be readily identified as being specific to a particular regulated industry or as […]


Four Credit Suisse Bankers Indicted for Helping U.S. Tax Payers Use Secret Accounts to Evade U.S. Taxes

Yesterday, the U.S Department of Justice (“DOJ”) and the Internal Revenue Service (“IRS”) announced that four (4) bankers at Credit Suisse Group AG (“Credit Suisse”) namely, Marco Parenti Adami, Emanuel Agustino, Michele Bergantino and Roger Schaerer, had been charged with conspiring with other Swiss bankers to help U.S. customers use secret accounts to evade U.S. […]


Treasury Identifies The Lebanese Canadian Bank Sal as Money Laundering Concern

On February 10, 2011, the U.S. Department of the Treasury (“Treasury”) announced the identification of The Lebanese Canadian Bank SAL, together with its subsidiaries (the “Bank”), as a financial institution of primary money laundering concern under Section 311 of the USA PATRIOT Act (Section 311) (the “Announcement”). According to Treasury, the Bank has been facilitating […]


FinCEN Issues Final Rule to Amend the Bank Secrecy Act Regulations

Today, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (“Final Rule”) to amend the Bank Secrecy Act (“BSA”) regulations regarding the Report of Foreign Bank and Financial Accounts (“FBARs”). The FBAR form is used to report a financial interest in, or signature or other authority over, financial accounts maintained outside of the United […]


Immigration Scam Shut Down by FTC

As a Human Resources Manager or In-House Counsel, you may be aware that it is common for foreign nationals to do their own research on U.S. Visa Requirements, accessing government websites relating to visa procedures and requirements. While U.S. government websites relating to such requirements have vastly improved in recent years, operations posing as the […]


IRS Announces 2011 Offshore Voluntary Disclosure Initiative

This week the U.S. government announced a new offshore voluntary disclosure initiative (“2011 OVDI”). Under this 2011 OVDI, taxpayers who voluntarily come forward and report their previously undisclosed foreign accounts and assets by August 31, 2011 will be excused from criminal prosecution. Will the 2011 OVDI Succeed? IRS Commissioner Shulman said in announcing the 2011 […]


India May Be Focus of IRS Foreign Account Investigations

Media reports in 2010 indicated that the Justice Department may be using data from India as a basis for opening investigations of U.S. taxpayers with suspected unreported offshore accounts at HSBC in India, Singapore, and Hong Kong.  Last month, Rick Raven, the IRS Deputy Chief for Criminal Investigations, reported that IRS Criminal Investigations Chief Victor […]


Does Your Bank Need Representation in Tallahassee?

Gunster has recently expanded its Tallahassee office, which is now home to the firm’s Government Affairs practice.  This 12-person team has a deep proficiency in government relations and navigates  all levels of state government-Executive, Administrative, Legislative and Regulatory.  Their experiences and relationships, as well as their presence in Tallahassee, make our government affairs team uniquely […]


FinCEN Issues Guidance Regarding Recent Events in Tunisia

On January 14, 2011, a wave of social protests ended Tunisian president’s Zine El Abidine Ben Ali (“Ben Ali”) 23-year old regime.  Ben Ali reportedly fled Tunisia for Saudi Arabia and is estimated to have amassed a fortune in excess of $5 billion as a result of the misappropriation of state assets and public corruption. […]


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