Farewell to 2023, and welcome 2024.  As we do every year, let’s look back.

We highlight 10 of our most-read blog posts from 2023, which address many of the key issues we’ve examined during the past year: criminal money laundering enforcement; compliance risks with third-party fintech relationships; the scope of authority of bank regulators; sanctions evasion — particularly sanctions involving Russia; cryptocurrency and digital assets; AML enforcement by the SEC; and BSA/AML compliance and its tension with de-risking.

We move on to 2024.  It will be another critical year, as the Corporate Transparency Act (“CTA”) is now in effect — with regulations pertaining to the alignment of the CTA and the Customer Due Diligence Rule still to come.  FinCEN also is expected to issue proposed regulations for the real estate industry, AML whistleblowing, and, potentially, investment advisors.  Criminal and regulatory enforcement relating to digital assets and fintech and third-party relationships will continue.  We look forward to keeping you informed throughout 2024 on these and other developments.

We also want to thank our many readers around the world who continue to make this blog such a success. The feedback we receive from financial industry professionals, compliance officers, in-house and external lawyers, BSA/AML consultants, government personnel, journalists, and others interested in this field is invaluable, and we hope you will continue to share your perspectives with us.  We pride ourselves on providing in-depth discussions of the important developments in this ever-evolving area.

If you would like to remain updated on these issues, please click here to subscribe to Money Laundering Watch.  Please click here to find out about Ballard Spahr’s Anti-Money Laundering Team.