FinCEN

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
News & Analysis as of

FinCEN Renewal of GTOs for High-End Cash Buyers in Six Markets

FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more

Bitcoin and Blockchain Technology Update: Research Paper

Locke Lord London Global Head of Cards & Payments Robert Courtneidge and Associate Charlie Clarence-Smith wrote a research paper on bitcoin and blockchain technology. Over the past few years, digital currencies have been...more

Navigating Through the Hazy Intersection of Financial Services and the Legal Marijuana Industry

As more states legalize marijuana use, financial institutions face increased uncertainty about how to handle accounts opened by marijuana-related businesses (MRBs) in light of regulatory difficulties stemming from the obvious...more

FinCEN Issues Advisory on Jurisdictions with AML/CFT Deficiencies

The Financial Crimes Enforcement Network (“FinCEN”), an agency within the U.S. Treasury Department, has put forth an Advisory on the FATFIdentified Jurisdictions with AML/CFT (Anti-Money Laundering/Combating the Financing of...more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

The Western Union DPA and the Need to Investigate One’s Own

The Western Union Company (“Western Union”) entered into a deferred prosecution agreement (“DPA”) on January 19th with the Department of Justice, based on alleged willful failures to maintain an effective AML program and the...more

No Seriously, When is My Return Due?

It’s that time of the year again. Or maybe it isn’t. Effective for tax years beginning on or after December 31, 2015, the filing deadlines for many common federal tax returns have changed. As a result, taxpayers coming...more

2016 Year in Review: Money Laundering (Part One)

2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

New Extended Due Dates for Foreign Bank Account Reports (FBAR)

All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or...more

Cyber$ecurity: Recent Developments in the Protection of Financial Data

As cybersecurity remains in the headlines moving into 2017, we consider recent developments in public policy concerning cybersecurity in the financial services industry....more

Cyber$ecurity: Recent Developments in the Protection of Financial Data

As cybersecurity remains in the headlines moving into 2017, we consider recent developments in public policy concerning cybersecurity in the financial services industry....more

Western Union to Pay $586 Million in Restitution and Civil Penalties for AML Compliance Failure

On January 19, 2017, Western Union Financial Services, Inc. agreed to pay civil penalties and restitution to victims of fraud totaling $586 million to resolve actions brought by the U.S. Treasury Department’s Financial Crimes...more

SEC Charges BD, COO With Failing to File SARs

The Commission has long focused on microcap fraud by, among other things, bringing manipulation actions centered on penny stocks. OCIE and FINRA have also issued guidance for compliance departments on red flags to watch for...more

Financial regulation in 2017: Europe and the US

The result of the UK referendum on its EU membership and the outcome of the US Presidential elections of 2016 have laid the ground for 2017 to be a year of transition for both Europe and the United States. As transitions are...more

Banking Problems for a Whole Industry

About half of the States have legalized marijuana for either or both medical and recreational use. Despite being legal under various state laws, businesses operating in the marijuana industry continue to encounter federal...more

Paying for the Wall: Will President Trump’s Administration Scrutinize, Tax, or Seize Remittances?

One of the most significant post-election questions for the financial-services industry—particularly global financial institutions that move money across borders—is what is the status of President-elect Trump’s proposal to...more

FinCEN Opens 2017 with SAR Sharing Guidance for Casinos

Financial institutions’ ability to share suspicious activity reports (“SARs”) within the corporate organizational structure serves as an important tool for Bank Secrecy Act compliance and risk avoidance. FinCEN began 2017 by...more

U.S. Senators Urge FINCEN to Update Guidelines on Legalized Marijuana

Later this year, the Pennsylvania Department of Health will award the first licenses for medical marijuana organizations. One of the requirements for these grower/processors and dispensaries, is that they must have a certain...more

FBAR Filing Deadline Extended for Certain Filers

On December 16, 2016, FinCEN issued Notice 2016-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over...more

Financial Services Weekly News - December 2016 #3

Editor's Note - The End of “Too Big to Fail”? On December 15, the Board of Governors of the Federal Reserve System (Federal Reserve Board) adopted a final rule to strengthen the ability of government authorities to...more

Filing Deadline Extended for Certain FBAR Filers

Certain individuals who have only signature authority over foreign financial accounts now have until April 15, 2018 to file the Report of Foreign Bank and Financial Accounts....more

Investment Management Update

IRS Issues Proposed Regulations Providing Guidance On The Tax Qualification Of Mutual Funds - On September 27, 2016, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) that provide...more

State Ballot Wins Only Amplify Questions About Pot Banking

The 2016 election will be remembered not only for the memorable presidential race but also for what was effectively a national referendum on cannabis. Eight states passed laws allowing its use. Medical marijuana is now...more

FinTech companies: Chartering relief is here

So you are an online lender, a digital currency company or a payments company, and you want to conduct business throughout the United States. How do you get licensed? Easy. You establish a corporate entity, register with...more

Nutter Bank Report, November 2016

Massachusetts Voters Approve Legalization of Marijuana for Recreational Purposes - Massachusetts voters have approved a ballot initiative legalizing the use of marijuana for recreational purposes, which will become law...more

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