Charles Horn

Charles Horn

Morgan Lewis

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FinCEN Requires Financial Institutions to Obtain Beneficial Ownership

FinCEN’s new CIP beneficial owner rules may hinder the ability of shell and nominee companies to directly access the US financial system without disclosing the natural persons who own 25% or more of the company. Pooled...more

6/1/2016 - Anti-Money Laundering Bank Secrecy Act Banks Beneficial Owner Broker-Dealer Commodity Pool Customer Due Diligence (CDD) Financial Institutions FinCEN Investment Adviser Investment Funds Mutual Funds Panama Papers Transparency

The Conference of State Bank Supervisors Adopts Model Regulatory Framework for Virtual-Currency Businesses

Addressing regulatory concerns pertaining to consumer protection, market stability, and law enforcement, the Framework expands on the CSBS draft framework released in December 2014. The Conference of State Bank...more

10/15/2015 - Bank Secrecy Act BitLicense CSBS Cybersecurity Disaster Preparedness Disclosure Requirements EFTA Licenses NMLS Notice Requirements NYDFS Regulatory Standards Risk Management Startups Third-Party Virtual Currency

AML Requirements Proposed for SEC Registered Advisers

On August 25, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury (Treasury), published a notice of proposed rulemaking (NPRM) to impose anti-money laundering (AML) programs and...more

9/2/2015 - Anti-Money Laundering Bank Secrecy Act Banking Sector Currency Transaction Reports (CTR) Financial Institutions FinCEN Investment Adviser Investment Advisers Act of 1940 Patriot Act Recordkeeping Requirements SEC Suspicious Activity Reports (SARs)

SEC Extends AML Relief for Broker-Dealer CIP Reliance on Advisers

The SEC’s action suggests that formal antimoney laundering program requirements for investment advisers may be on the horizon. On January 9, the staff of the U.S. Securities and Exchange Commission (SEC) issued the...more

1/19/2015 - Anti-Money Laundering Bank Secrecy Act FinCEN Investment Adviser No-Action Relief NOPR Reporting Requirements SEC SIFMA U.S. Treasury

FinCEN Proposes to Expand Financial Institution Customer Due Diligence Requirements

The proposal would require financial institutions to identify beneficial owners of legal entities and codify existing customer due diligence guidance....more

8/6/2014 - Anti-Money Laundering Bank Secrecy Act Banks Compliance Due Diligence FCMs FinCEN SEC

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