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You can also search for information [cviii], BitMEX Founders and Executives Guilty Pleas. We will email you Rather, the guidance notes OFACs expectation that financial institutions will make decisions on whether and how to screen transactions using instant payment systems based on each institutions assessment of its own risk. The information provided is not legal advice. The employees (one of whom was a mid-level manager) omitted the products Iranian country of origin information from relevant transactional documents, requested that the Thai supplier make no reference to Iran on its bills of lading, and told senior management and compliance personnel that the product was produced by the Thai supplier. [cxxxii] Off. Following a start high/stay high strategy, the Biden Administration imposed sanctions targeting prominent Russian financial institutions, state-owned entities, government agencies and officials, and oligarchs with unprecedented speed, breadth, and coordination with allied countries (including the United Kingdom, members of the European Union, Japan, Canada, and Australia). of Governors of the Fed. [xcii] DOJ Press Release, Russian Oligarch Charged with Violating U.S. Sanctions, (Apr. [cxxviii], Office of the Comptroller of the Currency, ICICI Bank. Failure to operate within the guidelines set by the Code and Zoning Resolution could result in violations, monetary penalties, and/or criminal charges. The violation is entered against the property in the Department's Buildings Information System (BIS), and must be corrected before a new or amended Certificate of Occupancy (CO) can be obtained. [xcix] Paul, Weiss, Biden Administration Warns of Increased Sanctions and Export Controls Enforcement, (Mar. [xxxvii] As in the related CA Indosuez (Switzerland) S.A enforcement action, OFAC determined CFM had reason to know of these violations given that the account holders know-your-customer files included address information indicating that they were resident in comprehensively sanctioned jurisdictions and that CFM had failed to implement and maintain the sanctions compliance framework of its parent company. 8, 2022), available here. [lxxxvii] SeeSarah N. Lynch and Luc Cohen,Veteran U.S. prosecutor to lead task force probing Russian oligarchs(Reuters, Mar. DOB Office Locations:Office Locations - Buildings (nyc.gov). The violation is entered against the property in the Department's, To remove a DOB violation from a property record, the condition must be corrected and proof of that correction must be provided to the issuing unit. Popular Bank. For the period January 1, 2014 through June 30, 2016, a total of 90,861 construction noise complaints were called in to New York . The most commonly issued violation is an Office of Administrative Trials and Hearings (OATH) Summons. [xliii] U.S. Dept of Treasury, OFAC Issues a Finding of Violation to Nodus International Bank, Inc. for Violations of the Venezuelan Sanctions Regulations and the Reporting, Penalties and Procedures Regulations (Oct. 18, 2022), available here. On April 1, 2022, FinCEN announced that A&S World Trading, Inc., d/b/a Fine Fragrance (A&S) had agreed to pay a $275,000 civil money penalty for failing to comply with a Geographic Targeting Order (GTO) applicable to certain nonfinancial trades and businesses located within the Los Angeles Fashion District. Distinguished Writing Award at the 2017 Burton Awards. Seizure of Roman Abramovichs Two Airplanes. No. What is a DOB Violation? If the owner repairs the problem and has it inspected and certified before that date, the hearing is cancelled and a new or revised Certificate of Occupancy is issued. Available here. [lxix] Paul, Weiss, FinCEN and OFAC Announce Settlements with Cryptocurrency Platform Operator Bittrex (Oct. 13, 2022), available here. Things we look for: [cxli], Wells Fargo Advisors. You can always avoid a complaint altogether and contact Burnham for a comprehensive review. of Currency, Joint Statement, Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence, at 1 (July 6, 2022). [xi] The White House, Executive Order on Taking Additional Steps to Address the National Emergency with Respect to the Situation in Nicaragua (Oct. 24, 2022), available here. However, the disclosure did not qualify as voluntary self-disclosure because OFAC was already in possession of the relevant information. of Comp. Litigation partner Jessica Carey and real estate partner Salvatore Gogliormella have been namedNew York Law JournalRising Stars for 2016. Misunderstanding of OFAC Sanctions or the Scope of OFAC General Licenses. Zoning Challenge. [xxix] According to OFAC, these 60 transactions occurred over a number of years and their total value was approximately $75,603,411. [c] DOJ Press Release, Justice Department Announces Charges and Arrests in Two Cases Involving Export Violation Schemes to Aid Russian Military (Oct. 19, 2022), availablehere. But it's also the driving force behind a lot of problematic marketing. In addition to issuing an unprecedented number of sanctions in response to the Russian invasion of Ukraine, Treasurys Office of Foreign Assets Control (OFAC) issued over a dozen enforcement actions, totaling nearly $43 million in civil penalties (more than double the amount that it had imposed in 2021). [xxii] U.S. Dept of Treasury, Treasury Designates DPRK Weapons Representatives, (Nov. 8, 2022), available here. OFAC encouraged financial institutions to use and implement such tools in a manner consistent with an institutions assessment of its sanctions-related risks. J.H. 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. The Department will not issue new or amended Certificates of Occupancy or Letters of Completion when DOB violations remain active. Danfoss FZCO directed customers located in Iran, Syria, and Sudan to make payments at this UAE branch. [xl] David Yaffe-Bellany, U.S. [vii] Based on public reporting, of the approximately seven billion dollars of DAB assets in the United States, the U.S. government is setting aside half ($3.5 billion) for the formation of a foundation in Switzerland to provide humanitarian aid to Afghanistan, and intends to shield the assets of this new foundation from both the Taliban and creditors of or litigants against the Afghan government. The Department for the Aging also issues violations to SADC providers that violate New York City Local Law 9 and New York State Office for the Aging Social Adult Day Services Standards. [xiv] See U.S. Dept of the Treasury, Venezuela General License 8J (May 27, 2022); U.S. Dept of Treasury, Venezuela General License 8K (Nov. 26, 2022), available here. Our practice also encompasses regulatory advice, compliance counseling and transactional due diligence. [cxxvii] As a result, the guidance emphasized that supervised banking organizations should notify their lead supervisory point of contact at the FRB (1) prior to engaging in any activity involving cryptocurrency, and (2) about any existing activity if they had not already done so. [lxviii]Noting that financial institutions are uniquely situated to detect possible financial exploitation, FinCEN called on financial institutions to identify, prevent, and report EFE to law enforcement and relevant Adult Protective Services at the state level. [xxxvi] U.S. Dept of Treasury, Office of Foreign Assets Control, OFAC Settles with CA Indosuez (Switzerland) S.A. for $720,258 Related to Apparent Violations of Multiple Sanctions Programs, (Sept. 26, 2022), available here. [clxxx] The Action Plan also outlined the U.S. governments seven priorities to address these risks: (1)monitoring emerging risks through the resources availability at various agencies; (2) improving global AML/CFT regulation and enforcement through work with the Financial Action Task Force (FATF) and other international agencies; (3) updating BSA regulations to address emerging financial technology; (4) strengthening domestic AML/CFT supervision of activity involving digital assets; (5)holding accountable cybercriminals and other illicit actors through cross-agency investigations and enforcement actions; (6)engaging with the private sector to ensure that it understands existing obligations and illicit financing risks, and regulatory obligations; and (7) supporting U.S. leadership in the financial technology space. WebECB Violations - NYC CityPay | City of New York CityPay Home Search for Tickets (Office of Administrative Trials and Hearings - OATH) There are three ways to search: By Ticket The violations stemmed from MidFirsts sanctions screening vendor notifying MidFirst that the individuals had been added to the SDN List 14 days later than they actually had. Its been a while since I started my role at Self-employed as a Attorney At Law, but I wanted to share this update with everyone. [lxii] The advisory focuses on Russian officials, citing the nexus between corruption, money laundering, malign influence and armed interventions abroad, and sanctions evasion within the country. As discussed in our prior memoranda,[ii] when Russias invasion of Ukraine began, the U.S. government reacted by issuing broad-ranging blocking sanctions targeting major Russian financial institutions and state-owned entities (including Sberbank, Alfa Bank VTB Bank, Alrosa, and the Russian Direct Investment Fund), as well as additional prominent Russian companies and individuals. [lxxxvii] The task force is staffed by prosecutors, agents, and analysts across DOJ with expertise in sanctions, export control, anticorruption, asset forfeiture, AML, tax enforcement, and national security investigations, as well as personnel from other departments and agencies, including the Department of Homeland Security and the IRS. The U.S. government also threatens sanctions (i.e., designation on the SDN List or some other form of sanctions) on non-U.S. persons who engage in certain types of transactions with designated Russian companies or who directly or indirectly support Russias war in Ukraine. Banco Popular de Puerto Rico. in the jurisdiction of Queens County. City of New York. [li] Specifically, the proposed rule provides that FinCEN may only disclose BOI to (i) federal agencies engaged in national security, intelligence, or law enforcement activities; (ii) state, local, and Tribal law enforcement agencies that obtain court authorization; (iii) U.S. Department of the Treasury officers and employees who require access in order to perform their official duties; (iv) certain authorized foreign law enforcement agencies and judicial and government authorities; and (v) financial institutions that need the information in order to comply with FinCENs 2016 CDD rule, provided that the relevant reporting company has consented to the disclosure. This appears to be the first bank regulator action against a bank for processing fraudulent PPP loans. [xxxvii] U.S. Dept of Treasury, OFAC Settles with CFM Indosuez for $401,039 Related to Apparent Violations of Multiple Sanctions Programs, (Sept. 26, 2022), available here. [cxlvii] The complaint alleges that while Darbie had devised AML protocols, it failed to implement them, which culminated in its failure to file SARs where the firm had reason to suspect illegal activity. Visit the, Applicable DOB civil penalty payments must also be made. You can always see your envelopes [ci] DOJ Press Release, Arrest and Criminal Charges Announced Against British and Russian Businessmen for Facilitating Sanctions Evasion of Russian Oligarchs $90 Million Yacht, (Jan. 23, 2023), available here. [clxxxi], The DOJ also released The Role of Law Enforcement in Detecting, Investigating, and Prosecuting Criminal Activity Related to Digital Assets.[clxxxii] The report discussed the manner in which illicit actors are exploiting digital asset technologies and the challenges that digital assets pose to criminal investigations. At GPARENCY we are starting to run the first drafts of all marketing using these tools and then the team takes over. 3, (Jun. [xx] According to OFAC, Blender was used to process tens of millions of dollars of cryptocurrency stolen by the Lazarus Group, a state-sponsored North Korean hacking group. WebDOB Building Information Search BIS is not reflecting some transactions made April 29 - May 6, 2022, as well as limited transactions prior to April 29 due to an unexpected power outage OFAC ultimately determined that the apparent violations were non-egregious and that CAIS had voluntarily self-disclosed the apparent violations. [iv] OFAC, FAQ 1055, (Jan. 17, 2023), available here. Pls pay it forward by liking and commenting to spread. Building Energy Efficiency Rating Label. Data Analysis, Data Collection, Market Insights, Market Research, WIKI [lxxiii] FinCEN also faulted Bittrex for failing to file SARs regarding certain transactions involving sanctioned jurisdictions.[lxxiv]. [clxvii] A DFS investigation found that MoneyGrams failure to oversee the activity of six of the companys agents was associated with a large spike in transaction volume of business with China from locations in New York City. [lxxxv] Paul, Weiss, Biden Administration Warns of Increased Sanctions and Export Controls Enforcement (Mar. 30, 2022), available here. OFAC determined that Nodus engaged in three transactions totaling $50,271.29 in violation of the VSR, as well as violating the RPPR, and failed to properly report blocked accounts. Detectors should be the type that beeps when the battery runs low. Thereafter, Reporting Companies will have 30 days to report any changes to FinCEN. [lviii] The rule also allows FinCEN to require participating financial institutions to impose additional internal controls to ensure data security and confidentiality of SAR information as a condition of participation in the pilot program. 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. [clxxix] In the Action Plan, Treasury outlined vulnerabilities and risks of AML and illicit financing in the cryptocurrency space, including the cross-border nature of transactions and gaps in AML/CFT regimes across countries, anonymity-enhancing technologies, the lack of the involvement of an intermediary financial institution to monitor transactions, and the inconsistent registration of Virtual Asset Service Providers. On January 11, 2022, OFAC announced a $5,228,298 settlement with Hong Kong-based Sojitz (Hong Kong) Limited (Sojitz HK), a trading and trade finance company, relating to 60 non-egregious apparent violations of the Iran sanctions program. The violationmust be corrected before a new or amended Certificate of Occupancy (CO) can be obtained. [clxxv] To address these priorities, the EO tasked various federal agencies with leading the review and ultimately issuing policy recommendations in roughly six months to one year depending on the study. If you need assistance finding a qualified trainer or obtaining cards for your crew, please call our office at 646-664-1800 for help. We are checking for the latest updates in this case. 10 (plea agreement) and Dkt. [clxx] In addition to the penalty, Coinbase agreed to invest an additional $50 million in its compliance function over the next two years to remediate the issues and to enhance its compliance program pursuant to a plan approved by DFS. of Comp. Please check back again soon Hsbc Bank Usa, N.A., As Trustee On Behalf Of Ace Securities Corp. Home Equity Loan Trust And For The Registered Holders Of Ace Securities Corp. Home Equity Loan Trust, Series 2006-He4, Asset Backed Pass-Through Certificates v. Jeffrey Jones AKA JEFFREY L JONES AKA JEFFREY D JONES AKA AAS JEFFERY JONES AKA JEFFREY N JONES, AKA JEFF JONES AKA JEFFREY J JONES AKA JEFFREY JOHN JONES AKA JOHN JEFFREY JONES AKA JEFFREY C JONES AKA JEFFREY A JONES AKA JEFFREY JONES AS ASSIGNEE OF JACQUELINE THOMAS, New York City Environmental Control Board (Fire And Building), New York City Parking Violations Bureau, New York State Department Of Taxation And Finance, First American Acceptance Co Llc, Great Seneca Financial Corp., Platinum Financial Services Corp, Royal Indemnity Co A/S/O, Criminal Court City Of New York, Criminal Court Of The City Of New York, Commissioner Of Social Services Nyc, John Doe, Jane Doe, Hsbc Bank Usa, N.A., As Trustee On Behalf Of Ace Securities Corp. Home Equity Loan Trust And For The Registered Holders Of Ace Securities Corp. Home Equity Loan Trust, Series 2006-He4, Asset Backed Pass-Through Certificates, Jeffrey Jones USAA. [clix] DFS found, among other things, that Robinhood Crypto (i) failed to maintain a compliant AML program as required by New Yorks Virtual Currency Regulation and as part of Robinhood Cryptos registration with DFS as a money transmitter; (ii) violated DFSs Part 504 regulation by failing to maintain an appropriate transaction monitoring system and submitting an improper certification of compliance; and (iii) violated DFSs Part 500 regulation by failing to maintain a compliant cybersecurity program and submitting an improper certification of compliance. Sold over $100 Million in property. This website uses cookies to improve your experience. Departments of Justice and Treasury Launch Multilateral Russian Oligarch Task Force (March 16, 2022), available here. [xxviii] U.S. Dept of the Treasury, Sanctions Compliance Guidance for Instant Payment Systems (Sept. 30, 2022), available here. WebAttention: The deadline for the new Site Safety Training (SST) cards is March 18, 2023. If detailed information is not available, you may request copies of DOB violations from the issuing unit. Approximately $850 million in penalties assessed by the SEC and the Danish authorities will be credited by DOJ. Contact DOB. On January 24, 2022, the FRB announced a $2.3 million consent order against Popular Bank for unsafe and unsound practices in connection with its processing of six Paycheck Protection Program (PPP) loansworth roughly $1.1 million in totaldespite having detected that the loan applications contained significant indications of potential fraud in a timely manner.[cxxxviii] According to the consent order, the bank did not timely report the indicia of potential fraud to the Small Business Administration, but rather continued to process and fund the loans, in violation of the Banks internal BSA protocols. Credit Union Admin., Off. Litigation partner John Carlin was featured in a Q+A in The Washington Posts latest issue of The Cybersecurity 202 newsletter. of Currency, at 1 (Aug. 29, 2022), available here. WebA DOB Violation is a notice that a property is not in compliance with some provision of applicable law and includes an order from the Commissioner of the Department of Under OFACs 50 percent rule, any entity owned 50 percent or more in the aggregate by one or more SDNs is treated as though it were an SDN, such that the prohibitions of the SDN List effectively apply to thousands of Russian entities. [lxxvi] FinCEN Press Release, FinCEN Announces $ 140 Million Civil Money Penalty against USAA Federal Savings Bank for Violations of the Bank Secrecy Act (March 17, 2022), available here. To view violations on your property, access the, Detailed information on certain DOB violations is available in BIS. [cxxxix] The SEC stated that it would emphasize review for compliance programs that would, inter alia, identify and verify the identity of customers, conduct due diligence on customers, monitor for suspicious activity, and allow for the filing of SARs with the SEC. City of New York. [xlviii] U.S. Dept of Treasury, U.S. Treasury Blocks Over $1 Billion in Suleiman Kerimov Trust, (Jun. 13, 2022), available here. We will email you this document in the next few minutes once we acquire it. [xv] U.S. Dept of Treasury, Venezuela General License 40A (Jul. Failing to maintain the inside temperature at 68 degrees when the outside temperature is below 55 degrees during the day, or The comment period closed on February 21, 2022.[lvi]. In addition to continuing its rulemakings to implement the Anti-Money Laundering Act of 2020 (AML Act), FinCEN issued three consent orders in 2022, totaling nearly $170 million, which is less than the over $300 million imposed the prior year. [cxlvi] The SEC settlement is part of a global resolution that also includes the DOJ and Denmarks Special Crime Unit. The proposed rule outlines circumstances in which authorized recipients can request access to the BOI contained in FinCENs database and the data protection protocols and oversight mechanisms that apply. Nodus International Bank. [clxiii] The DFS found that the New York branch allowed serious compliance deficiencies to persist for years despite repeated regulatory warnings.[clxiv] The order notes that in 2020, the head office changed management at the branch and instituted various remedial measures. The processing fee is $8.00 per copy for each violation; each additional duplicate copy of a violation is $5.00. Along with the redesignation, OFAC also issued an FAQ that clarified that (i) OFAC viewed Tornado Cash as meeting the definition of person in the relevant executive orders (a partnership, association, trust, joint venture, corporation, group, subgroup, or other organization) and (ii) neither the founders of Tornado Cash nor the members of the Tornado Cash Decentralized Autonomous Organization are the target of sanctions; rather, it is the Tornado Cash privacy protocol itself that is the target of sanctions. Litigation partners Jessica Carey and Roberto Gonzalez have been selected to receive the Law360 Distinguished Writing Award at the 2017 Burton Awards. WebFind Building Data Using tools like the Building Information System (BIS) and the DOB NOW Public Portal, you can review the history of any building in New York City. If you have any questions, Ask us Anything. After attempted payment of the invoice was rejected by a U.S. financial institution due to sanctions-related concerns multiple times between August 2015 and 2016, S&P Global employees re-issued and re-dated the August 2015 invoice several times between August 2016 and October 2017 as Rosneft made partial payments. Commn v. J.H. [liii] Congressional Budget Office, At a Glance: H.R. OFAC stated that these apparent violations occurred when the company used its Hong Kong-based bank to make USD-denominated payments, which routed through U.S financial institutions, to purchase Iranian-origin high density poly ethylene (HDPE) from a Thailand-based supplier for ultimate resale to buyers located in China. [clxxxv], On October 21, 2022, the first Plenary of the Financial Action Task Force (FATF) issued guidance identifying jurisdictions under increased monitoring and those subject to a call for action.[clxxxvi] Jurisdictions under increased monitoring are those that are actively working with the FATF to address the strategic deficiencies in their regimes to counter money laundering, terrorist financing, and proliferation financing.[clxxxvii] New jurisdictions subject to increased monitoring included the Democratic Republic of Congo, Mozambique and Tanzania. I have 7 minutes, pitch me now. The pilot program would terminate on January 1, 2024 but could be extended by the Treasury Secretary for up to two years upon notice to Congress. Russian Elites High-Value Assets Alert. When expanded it provides a list of search options that will switch the search inputs to match the current selection. [lix] FinCEN has urged financial institutions to file suspicious activity reports and conduct customer due diligence as appropriate. [xxxiii] U.S. Dept of Treasury, OFAC Settles with American Express National Bank for $430,500 Related to Apparent Violations of Foreign Narcotics Kingpin Sanctions Regulations, (Jul. Successful whistleblowers would receive at least 10 percent of a collected penalty that exceeds $1 million, up to a 30 percent cap. [cxxix] Off. This will halt all forward motion in construction and the selling of the property until the violations are cleared up. [lxxxvi] DOJ Press Release,Attorney General Merrick B. Garland Announces Launch of Task Force KleptoCapture(Mar. [clxxv] Executive Order, supra note 173. Litigation counsel David Kessler co-led a panel as part of the 2022 London Global Conference hosted by the New York State Bar Associations International Section. NYC Department of Buildings Self-service for online Permits, Appointments and Applications Login DOB NOW: BUILD, LICENSING, SAFETY and BIS OPTIONS will be For much of 2022, OFAC largely maintained the status quo with respect to the Venezuela sanctions program, issuing some limited guidance regarding the ability of U.S. persons to deal in certain debts of Venezuela to modify references to outdated benchmarks (e.g., LIBOR)[xiii] and twice extending a license permitting certain listed U.S. energy companies to continue to engage in maintenance activities through early 2023 relating to pre-existing projects in Venezuela that involve sanctioned state-owned Venezuelan energy companies. On August 8, 2022, DOJ announced that it would seize an airplane valued at over $90 million and owned and controlled by Andrei Skoch, a Russian SDN, pursuant to a seizure warrant from the U.S. District Court for the Southern District of New York. [lxxxviii] Tightening the Screws on Russia: Smart Sanctions, Economic Statecraft and Next Steps Statement of Andrew Adams, Hearing Before the S. Comm. for this document. at 3; see also Paul Weiss, Biden Administration Warns of Increased Sanctions and Export Controls Enforcement (March 8, 2022), available here. April 4, 2022, What is Market Research? The guidance makes clear that developers of instant payment systems and financial institutions that participate in instant payment systems (like all financial service providers) are responsible for ensuring that they do not engage in unauthorized transactions prohibited by U.S. sanctions and that, therefore, such businesses should develop a tailored, risk-based sanctions compliance program in line with the guidance provided by OFAC in itsFramework for OFAC Compliance Commitmentsas well as the guidance. [cxxvi] The FRB confirmed that it is closely monitoring related developments and banking organizations participation in crypto-asset-related activities due to these risks. WebHPD Online Use HPD Online to find building data and information about complaints and litigation, property registration, violations and charges, and block and lot information. I was on the Jersey Shore, between treating patients as a physical therapist doing house calls. Corp., Fin. President Bidens Proposal to Facilitate Russia-Related Asset Seizures. On February 24, 2022, the DFS Superintendent announced a $35 million consent order against the National Bank of Pakistan and its New York Branch for AML compliance failures. On April 25, 2022, OFAC announced a $6,131,855 settlement with Australia-headquartered Toll Holdings Limited (Toll) related to 2,958 apparent violations of multiple sanctions programs, including transactions with individuals on the SDN List as well as transactions involving North Korea, Iran, and Syria. DOB NOW: BUILD, LICENSING, SAFETY and BIS OPTIONS will be unavailable due to system maintenance on Friday March 3, 2023 at 6:00 p.m. until Sunday March 5, Services, In the Matter of Robinhood Crypto, LLC (Aug. 2, 2022), available here (hereinafter, the DFS Order); N.Y. Dept of Fin. 7, 2022), available here. Newmont Corporation and Chisu International Corporation. Reserve Sys., Fed. As relevant here, the EO noted the role of digital assets in sophisticated cybercrimerelated financial networks and activity, including through ransomware activity.[clxxvi] The EO called for a cross-governmental team of law enforcement agencies to submit multiple reports to address this riskincluding one that is to be submitted to Congress on the trends in the use of digital assets by illicit actors. Danske Bank Estonia processed $160 billion through U.S. banks on behalf of these customers. [xxx] Danfoss A/S is a Danish manufacturer and seller of refrigeration products, air conditioners, compressors, and other cooling products. From new constructed buildings to the older pieces of architecture, there is an existing lack of accessibility. In total, through the end of 2022, federal and state authorities imposed approximately $3.88 billion in penalties and asset seizures for AML/sanctions violations. The Global Table Linen Market 2022 research report is based on an exhaustive study of the market, enabling customers to gain access to potential forecasts and requirements. I got that question today and I took a moments pause. Exposure to the #radtech and patients is greater with portable units than with fixed units. FinCEN found that Harmon operated an unregistered MSB in violation of the BSA and deliberately disregarded his obligations under the BSA, including by failing to collect and verify customer names, addresses, and other identifiers on over 1.2 million transactions. Proposed Rulemaking Regarding Access to Beneficial Ownership Information.
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