Dimitar Georgiev

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Proposed FinCEN Pilot Program on Sharing of Suspicious Activity Reports with Foreign Affiliates

On January 25, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued its anticipated Notice of Proposed Rulemaking seeking public comment on a proposed pilot program that would permit certain financial institutions to share suspicious activity reports (“SARs”) and information related to SARs with the institutions’ foreign branches, subsidiaries, and affiliates (the “NPRM”). The proposed rule is … Continue Reading

The Biden Administration Announces Strategy to Combat Global Corruption

On December 6, 2021, the White House (the “WH”) released the first United States Strategy on Countering Corruption (the “Strategy”) that sets the Biden-Harris Administration’s goals to tackle international corruption. Much of the Strategy remains currently aspirational and requires additional legislative and regulatory action to implement. Still, it signals the direction the Administration is looking … Continue Reading
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