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AML/Money Laundering


Please join us for a weekly series, hosted by Baker McKenzie’s North America Government Enforcement partners Jeffrey Martino and Jerome Tomas.
This weekly briefing is available on demand and will cover hot topics and current enforcement actions related to white collar crime and criminal investigations in the US and abroad to arm you with the information you need for your business week.
This week’s discussion covers Deputy Attorney General Lisa Monaco’s memorandum revising Federal Corporate Criminal Enforcement Policies.

Anti-Money Laundering and Combating the Financing of Terrorism measures play an important role for financial institutions and specified non-financial businesses (collectively referred to as Reporting Entities), to combat money laundering and the financing of terrorism. The relevant AML/CFT laws, regulations and guidelines have been continuously improved in order to comply with international standards. To keep up with the dynamic and evolving regulatory developments, Baker McKenzie has issued this publication to provide an overview of Thailand’s AML/CFT regulations and guidelines.

On 24 November 2021, the Bank of Italy issued an order concerning amendments to the Bank of Italy’s Circular No. 285 of 17 December 2013 on “Supervisory provisions for banks” (the “Circular No. 285”). The amendments to the Bank of Italy’s Circular No. 285 aim at aligning the Italian regulations with the latest EU legislative developments on sound remuneration policies and practices, in particular exempted entities, financial holding companies, mixed financial holding companies, remuneration, supervisory measures and powers and capital conservation measures.

In our previous newsletters, we explored the first two key legal obligations of non-financial businesses under the Money Laundering Control Act, B.E. 2542 (1999): reporting obligations and know-your-customer (KYC) and customer due diligence (CDD) procedures. In this article we will discuss the third and fourth key legal obligations: implementing internal policies and procedures to address the risk of money laundering, and coordinating with the Anti-Money Laundering Office (AMLO) to provide training for personnel.

On October 15, 2021, the US Treasury Department’s Office of Foreign Assets Control published sanctions compliance guidance for the virtual currency industry (the “Guidance”), given that “the growing prevalence of virtual currency … brings greater exposure to sanctions risk.” This Guidance follows (1) the recent and first-ever designation of a virtual currency exchange by the OFAC (see our recent post on this here), and (2) the launch of the National Cryptocurrency Enforcement Team to tackle criminal misuses of cryptocurrency (see a description of this new team on our Blockchain blog, available here).

In this episode of TMT Talk, Harry Valetk, is joined by Tiago Zapater, a litigation partner at Trench Rossi Watanabe in Brazil, to discuss the monetization challenges in video games. Listen in to learn how video games sell and make money, loot boxes and their significance in the region, recent decisions and class actions in Brazil and much more.

For a little over a year now, the financial sector has been occupied with the need for resilience in the face of the challenges posed by the pandemic, but we are now swiftly and surely moving into the reform and renewal stages of recovery. It’s now time to reflect on what is changing as well as the lessons we have learnt so that the financial sector can continue to best serve and support its clients and markets.

This is a reminder that 30 September 2021 is the legal deadline for companies that receive foreign investment and that have assets or equity exceeding BRL 250 million to comply with the Declaration of Economic and Financial Information by submitting their financial data related to the base-date of 30 June 2021 in the Central Bank’s System, as per Resolution No. 3,844 of 23 March 2010 of the Brazilian National Monetary Council and Circular No. 3,814 of 7 December 2016 of the Central Bank.