December 6, 2021

Volume XI, Number 340

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December 06, 2021

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December 03, 2021

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FinCEN Highlights Environmental Crimes and Related Illicit Financial Activity

FinCEN alerted financial institutions to an uptick in environmental crimes and related illicit financial activity.

FinCEN explained that these "crimes include (i) wildlife trafficking, (ii) illegal logging, (iii) illegal fishing, (iv) illegal mining, and (v) waste and hazardous substances trafficking." FinCEN called these crimes "relatively low risk activities with high rewards because enforcement efforts are limited, demand for the products and services generated by these crimes is high, and criminal penalties are not as severe as for other illicit activities."

FinCEN stated that "environmental crimes frequently involve transnational organized crime and corruption and are often associated with a variety of other crimes including money laundering, bribery, theft, forgery, tax evasion, fraud, human trafficking, and drug trafficking."

FinCEN highlighted the "need to enhance reporting and analysis of related illicit financial flows." In the alert, FinCEN (i) offered financial institutions suspicious activity report filing instructions that are specific to environmental crimes, and (ii) underscored the likelihood of illicit financial activity associated with them.

As recently covered, FinCEN held a virtual FinCEN Exchange to identify illicit financial flows and money laundering related to environmental crimes.

© Copyright 2021 Cadwalader, Wickersham & Taft LLPNational Law Review, Volume XI, Number 322
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