As described in our prior memorandum, on January 18, 2023, FinCEN made its first use of its authority under section 9714 of the Combating Russian Money Laundering Act by issuing an order prohibiting covered financial institutions from transmitting funds with the non-U.S. FinCEN also found that Bitzlato facilitates a substantially greater proportion of money laundering activity in connection with Russia-affiliated ransomware actors and darknet markets than other cryptocurrency exchanges. Proposed Rulemaking Regarding Access to Beneficial Ownership Information. On December 15, 2022, FinCEN issued a Notice of Proposed Rulemaking to implement provisions of the CTA that concern access to and protection of beneficial ownership information. The CTA requires Reporting Companies to report BOI to FinCEN, and FinCEN will in turn establish a BOI database.

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In 2017, a Nodus customer was added to the SDN List and Nodus decided to sever all ties with the customer. In the course of doing so, Nodus, sought to redeem the customer’s interest in certain securities that were issued by Nodus prior to the individual’s designation. Although Nodus understood it needed a license from OFAC to process the redemption after the designation, it did not apply for one. Nodus also, as a result of human error, permitted an automatic debit from one of the customer’s accounts to credit the customer’s outstanding credit card balance.

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At age six, she and two friends from the school performed a play there for Black History Month. She grew as a performer in part at the nearby California Shakespeare Theater in Orinda, California, where her mother worked a summer job as the house manager. She helped her seat patrons, sold fundraising tickets, and was inspired by the theatrical performances to pursue acting. At eight, Zendaya joined a hip-hop dance troupe called Future Shock Oakland and was a member for three years.

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Economic Sanctions and Anti-Money Laundering Developments: 2022 Year in Review

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USAA admitted to willfully failing to implement and maintain an AML program that met the BSA’s minimum requirements for a period of over five years. It also admitted that it willfully failed to timely report thousands of suspicious transactions to FinCEN. FinCEN credited the OCC $60 million penalty against the $140 million figure. The GTO, which was effective from October 9, 2014 through April 6, 2015, required covered business to report cash transactions that exceeded $3,000 by electronically filing a report with FinCEN. FinCEN found that A&S failed to report at least 114 cash transactions totaling approximately $2,330,000, violating the reporting and recordkeeping requirements of the GTO. Moreover, the company failed to correct these failures even after the Internal Revenue Service (“IRS”) identified the 114 missing GTO reports during an examination in September 2015.