Last year, Congress passed the first major overhaul of the Bank Secrecy Act ("BSA") in fifty years. The new law requires certain entities to report the identities of their beneficial owners, enhances the government’s ability to obtain foreign bank records, creates new reporting requirements for cryptocurrencies and antiquities dealers, expands the powers and duties of FinCEN, enhances inter-agency information sharing, and establishes a new whistleblower program for violations of the BSA. This panel explains these new provisions and how they could affect your clients.
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Mr. Comisky is the Chair of International Compliance with the law firm of Fox Rothschild LLP. Mr. Comisky concentrates his practice in the areas of civil and criminal tax litigation, anti-money laundering compliance and complex corporate and commercial litigation. Mr. Comisky is the co-author of Tax Fraud and Evasion which contains chapters dealing with money laundering and FATCA compliance issues. Mr. Comisky represents both corporations and individuals in criminal tax investigations, both administrative and grand jury. Mr. Comisky has represented individuals and entities in connection with issues relating to foreign bank accounts and has represented foreign financial institutions in connection with FATCA compliance. Mr. Comisky has also been retained on banking and other corporate compliance matters primarily relating to Bank Secrecy Act and related money laundering and asset forfeiture issues. Mr. Comisky has also been retained by directors and officers in civil and criminal securities litigation involving tax and accounting issues. Mr. Comisky has further handled other commercial litigation including RICO class action and other complex commercial disputes primarily in federal courts in Philadelphia and Florida. Mr. Comisky is an adjunct professor at the University of Pennsylvania law school teaching a course in money laundering.