Treasury issued a final rule requiring certain investment advisers to establish an AML/CFT Program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Final Rule).
The Final Rule applies to...more
9/11/2024
/ AML/CFT ,
Bank Secrecy Act ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Notice of Proposed Rulemaking (NOPR) ,
Policies and Procedures ,
Registered Investment Advisors ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
The Proposed Rule would require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish, document and maintain written customer identification programs (CIPs).
The Proposed Rule comes...more
6/5/2024
/ AML/CFT ,
Bank Secrecy Act ,
Beneficial Owner ,
Customer Identification Program (CIP) ,
Exempt Reporting Advisers (ERAs) ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Notice Requirements ,
Proposed Rules ,
Recordkeeping Requirements ,
Securities and Exchange Commission (SEC)
On April 18, 2023, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) Assistant Secretary for Export Enforcement, Matthew Axelrod, published a memorandum marking a shift in policy regarding voluntary...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a proposed rule (Proposed Rule) on December 15, 2022, implementing the requirements of Section 6403 of the Corporate Transparency Act (Act)...more
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on September 29, 2022 issued a final rule (Final Rule) defining and implementing the beneficial ownership reporting requirements of Section 6403...more
12/1/2022
/ Anti-Money Laundering ,
Beneficial Owner ,
Commodity Exchange Act (CEA) ,
Corporate Transparency Act ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Investment Advisers Act of 1940 ,
Investment Company Act of 1940 ,
Limited Liability Company (LLC) ,
Ownership Interest ,
Pooled Investment Vehicles ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act of 1934
On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed new regulations (“Proposed Regulations”) defining and implementing the beneficial ownership reporting...more
12/23/2021
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Transactions ,
FinCEN ,
Money Laundering ,
Proposed Regulation ,
Regulatory Requirements
The Anti-Money Laundering Act of 2020 (AML Act), enacted on January 1, 2021 as part of the National Defense Authorization Act for Fiscal Year of 2021 (NDAA), makes several significant changes to U.S. anti-money laundering...more
2/23/2021
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Disgorgement ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
NDAA ,
New Legislation ,
Pooled Investment Vehicles ,
Regulatory Agenda ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
Suspicious Activity Reports (SARs) ,
Whistleblowers
On November 5, 2018, applicable wind-down periods for certain transactions with Iran ended and the second and final set of U.S. secondary sanctions that had been lifted pursuant to the Iran nuclear deal – the Joint...more
11/7/2018
/ Blocking Statutes ,
Economic Sanctions ,
Energy Sector ,
EU ,
Exports ,
FinCEN ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Iran ,
Iran Sanctions ,
Joint Comprehensive Plan of Action (JCPOA) ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Secondary Sanctions ,
Shipping ,
Special Purpose Vehicles ,
Trump Administration
Recent enforcement actions brought by the U.S. Government against non-U.S. banks for violations of U.S. sanctions laws demonstrate the need for financial institutions, particularly those that act as custodians or financial...more
1/30/2014
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Compliance ,
FinCEN ,
Foreign Banks ,
Iran ,
ITSR ,
Office of Foreign Assets Control (OFAC) ,
Sanctions ,
U.S. Treasury