Full Description
We are happy to provide the eighth annual edition of ICLG - Anti-Money Laundering. As always, we think you will find the new edition useful and informative.
During the last year of the Biden Administration, U.S. authorities continued to focus on enforcement related to sanctions evasion and anti-money laundering ("AML"). The conflicts in Ukraine and the Middle East highlighted that effective measures to stem money laundering related to sanctions evasion are imperative. Further, U.S. authorities continue to enforce AML laws and regulations to address narcotics trafficking, fraud schemes, cybercrime, and ransomware attacks. Authorities took action against both traditional financial institutions and digital asset companies to enforce AML laws.
In the United States and elsewhere, authorities also expanded regulations applicable to modernise the AML legal and regulatory regime, and to make the overall AML regime more risk-based and effective by applying the technology of today to AML compliance and improving the public and private exchange of information to enhance the quality of suspicious activity reporting. In 2024, the United States finalised rules applying new or additional AML controls to the real estate industry and investment advisers. In accordance with provisions in the AML Act of 2020, the United States has established a national, non-public corporate registry with beneficial ownership information, but recent developments have made the future of that registry unclear.
It is possible that additional regulatory and enforcement changes will be made in 2025 by the Trump Administration in the U.S. money laundering space, which could also impact international efforts and regulations. In the first few weeks of the Trump Administration, the President and his Attorney General Pam Bondi have issued executive orders and memoranda directly relevant to money laundering and sanctions enforcement. 2025 and the years to come will remain important periods in the fight against money laundering.
Gibson, Dunn & Crutcher LLP is honoured to join a group of distinguished colleagues to present several articles on AML topics that we hope you will find of interest. Global Legal Group has also included chapters written by select law firms in 15 jurisdictions, discussing the local AML legal and regulatory/administrative, as well as enforcement, requirements. Gibson Dunn is pleased to include a chapter discussing some of the most notable AML developments in the United States in 2024/5.
As with all ICLG guides, this Guide is organised to help the reader understand the AML landscape globally and in specific countries. Global Legal Group, the editors, and the contributors intend this Guide to be a reliable first source when approaching AML requirements and considerations. We encourage you to reach out to the contributors if we can be of further assistance.
Contents
Expert Analysis Chapters
1
Top Developments in Anti-Money Laundering Enforcement in 2024
M. Kendall Day, Stephanie Brooker, Ella Alves Capone & Sam Raymond, Gibson, Dunn & Crutcher LLP
10
The UAE's AML Transformation: A Review
David Berman & Gabrielle Margerison, White & Case LLP
16
The Role of the Board of Directors in Anti-Money Laundering Law Compliance
Matthew Biben & Olivia Radin, King & Spalding LLP
21
Anti-Money Laundering in the Asia-Pacific Region: An Overview
Dennis Miralis, Harry Sultan, Henry Yu & Zanthi Jordan, Nyman Gibson Miralis
Q&A Chapters
33
Australia
Dennis Miralis, Kartia Zappavigna, Jasmina Ceic & Jack Dennis, Nyman Gibson Miralis
43
Cayman Islands
Ian Paget-Brown KC & Megan Paget-Brown, Paget-Brown Chambers
51
France
Thierry Marembert, Cécile Labarbe & Aaron Bass, Kiejman & Marembert
58
Germany
Dr. Dirk Seiler & Dr. Daisy Hullmeine, Herbert Smith Freehills LLP
67
Greece
Ilias Anagnostopoulos & Alexandros Tsagkalidis, Anagnostopoulos
75
India
Faraz Sagar, Sara Sundaram & Kritika Angirish, Cyril Amarchand Mangaldas
89
Isle of Man
Caitlin Gelder, Kathryn Sharman & Sinead O'Connor, DQ Advocates Limited
96
Liechtenstein
Dr. Stefan Wenaweser, Dr. Julia Köpf, Katharina Hasler & Julian Maikisch, Marxer & Partner Attorneys at Law
106
Mexico
Guillermo A. Moreno M., Santamarina y Steta, S.C.
112
Netherlands
Jurjan Geertsma & Luca van der Hoeven, JahaeRaymakers
121
Romania
Simona Pirtea & Mădălin Enache, ENACHE PIRTEA & ASSOCIATII S.p.a.r.l.
129
Singapore
Gary Low & Terence Tan, Drew & Napier LLC
140
Switzerland
Cornelia Stengel & Lea Ruckstuhl, Kellerhals Carrard
150
United Kingdom
Jonah Anderson & Anneka Randhawa, White & Case LLP
162
USA
M. Kendall Day, Stephanie Brooker, Ella Alves Capone & Sam Raymond, Gibson, Dunn & Crutcher LLP
