On February 16, 2018, FinCEN issued a NPRM that set forth FinCEN’s findings of money laundering concern regarding Latvian bank ABLV, which promptly collapsed in the wake of the announcement and has spent the subsequent years undergoing a lengthy and at times controversial liquidation process..
FinCEN deemed ABLV to be a foreign financial institution of primary money laundering concern, but now that it has no banking license and has nearly completed its liquidation process, ABLV "no...