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Bank Secrecy Act › Reporting Requirements

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
Goodwin

FinCEN Adopts Reporting Requirement for Non-Financed Residential Real Estate Transfers

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Residential Real Estate Rule) requiring certain persons involved in residential real estate closings and...more

Rivkin Radler LLP

Unconstitutionally Excessive FBAR Penalties? It Depends

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You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

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On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

Eversheds Sutherland (US) LLP

FinCEN adopts investment adviser AML rules

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The Financial Crimes Enforcement Network (FinCEN) adopted a final rule that adds most federal Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to the definition of “financial institution” under the...more

Locke Lord LLP

FINCEN Adopts New Rule on Cash Sales ‎of Residential Real Estate

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On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) published a final rule (the “Rule”) requiring reports by “reporting persons” concerning real estate transfers to a legal entity or trust of certain...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Finalizes Rule to Compel Reporting of Individuals and Beneficial Ownership of Entities Involved in Specified Transfers of...

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FINCEN’s final rule (RRE Rule), effective December 1, 2025, will require disclosure of the transferor and transferee(s) and the individuals and the beneficial owners of entities involved as transferee in the transfer of...more

Lowenstein Sandler LLP

The Real (Estate) Deal: FinCEN’s New Reporting Requirements for Property Transfers

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In response to illicit finance risks identified in the U.S. residential real estate sector, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced the issuance of its long-anticipated...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

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The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

Ballard Spahr LLP

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

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The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more

Foodman CPAs & Advisors

Acceso A BOI: Enfoque Gradual De FinCEN

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El 4/18/24, FinCEN actualizó su sección de preguntas frecuentes y agregó una nueva sección titulada “Acceso a información de BOI”. Esta nueva sección aborda el enfoque gradual de FinCEN para brindar acceso a BOI (información...more

Foodman CPAs & Advisors

Access To BOI: FinCEN Phased Approach

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On 4/18/24, FinCEN updated its FAQ Section and added a new section titled “Access to BOI Information”. This new section addresses the phased approach from FinCEN to providing access to BOI – beneficial ownership information –...more

Ballard Spahr LLP

FinCEN Issues Reminder to Financial Institutions to Identify and Report Elder Financial Exploitation

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On June 14, 2024, President Biden declared June 15th World Elder Abuse Awareness Day.  In honor of the day, the Financial Crimes Enforcement Network (FinCEN) reminded financial institutions (FIs) to remain vigilant in...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

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On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Jenner & Block

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

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In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more

K2 Integrity

[Webinar] AML/CFT Rules for Investment Advisers - June 12th, 9:30 am PT

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On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

Foodman CPAs & Advisors

Directora Gacki De FinCEN Fomenta La Transparencia En El Sistema Financiero De EE. UU

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Durante la Conferencia Anual contra el Lavado de Dinero de FIBA (“Financial and International Business Association”) celebrada el 18 al 21 de marzo de 2024 en Miami, Florida, la Directora Gacki de FinCEN discutió las...more

Ballard Spahr LLP

IRS Unveils Broad Draft Information Reporting Form for Digital Asset Transactions

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On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more

Fox Rothschild LLP

IRS Issues New Guidance for Cannabis Companies That Receive Over $10K in Cash

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The IRS’s Office of Chief Counsel recently published a memorandum providing information for cannabis companies struggling to comply with the completion of Form 8300, which must be filed every time a company receives a cash...more

Fox Rothschild LLP

IRS Issues New Guidance for Cannabis Companies That Receive Over $10K Cash

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The IRS’s Office of Chief Counsel recently published a memorandum providing information for cannabis companies struggling to comply with the completion of Form 8300, which must be filed every time a company receives a cash...more

WilmerHale

FinCEN Re-Proposes AML/CFT Requirements Covering Investment Advisers

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On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more

Dechert LLP

Treasury Proposes Investment Advisers AML/CFT Program Rule

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Treasury proposed a new rule that would require investment advisers to establish an AML/CFT program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Proposed Rule). The Proposed Rule...more

Moritt Hock & Hamroff LLP

MHH Condo/Co-op Digest, Vol. V - March 2024

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This newsletter explores the emerging legal topics and issues affecting the condominium and cooperative services industry. Thought-leading attorneys from Moritt Hock & Hamroff’s Condominium and Cooperative Services Practice...more

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