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Patriot Act Financial Institutions

Seward & Kissel LLP

Department of the Treasury Releases New AML/CFT Rule for Investment Advisers

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Who may be interested: Investment Advisers - Quick Take: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule subjecting certain registered investment advisers (RIAs) and...more

Seward & Kissel LLP

Q&A on FinCEN’s New AML Requirements for Certain Investment Advisers

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

K&L Gates LLP

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

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Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

Foodman CPAs & Advisors

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

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

Foodman CPAs & Advisors

Director Gacki From FinCEN Encourages Transparency In The U.S. Financial System

During the FIBA’s (Financial and International Business Association’s) annual anti-money laundering conference held from March 18, 2024, to March 21, 2024 in Miami, Florida, Director Gacki from FinCEN discussed regulatory...more

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

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On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

K2 Integrity

FinCEN Proposes New Regulation To Enhance Transparency In Convertible Virtual Currency Mixing And Combat Terrorist Financing

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Summary of What Has Happened and What Is Yet to Come - On 19 October 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rule Making (NPRM), pursuant to...more

Eversheds Sutherland (US) LLP

FinCEN proposes new recordkeeping and reporting rule for convertible virtual currency mixing

On October 19, 2023, The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM) taking aim at convertible virtual currency (CVC) mixing transactions,...more

Orrick, Herrington & Sutcliffe LLP

FinCEN highlights use of BSA reporting data

On April 25, FinCEN released its year-in-review for FY 2022. The annual summary provided insights into the agency’s efforts to support law enforcement and national security agencies, as well as statistics from Bank Secrecy...more

Lowenstein Sandler LLP

Silicon Valley Bank Fallout: Navigating and Managing the Account Opening Processes at Other Financial Institutions

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Silicon Valley Bank, Santa Clara, California, was closed on March 10 by the California Department of Financial Protection and Innovation (CDFPI). On March 12, the New York State Department of Financial Services (NYSDFS)...more

K2 Integrity

How Efforts to Counter Terrorist Financing Have Evolved Since 9/11

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Since 9/11, countering the financing of terrorism (CFT) has been a focus of U.S. and international security policy, and an evolving feature of the regulatory and risk environment for authorities and the private sector. In the...more

Venable LLP

Keeping up with Anti-Money Laundering Rules

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In 1970, Congress passed the Currency and Foreign Transactions Reporting Act, commonly known as the “Bank Secrecy Act” (BSA). The BSA is often referred to as an “anti-money laundering” (AML) law or jointly as “BSA/AML.” The...more

K2 Integrity

Sanctions Against Russia: Understanding the Evolving Picture and How to Respond

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...Since the start of the invasion of Ukraine by Russian forces on February 24, the United States (U.S.), United Kingdom (UK), and the European Union (EU) have led a global sanctions campaign against Russia that has been...more

Perkins Coie

Recent Developments in US Sanctions and Export Controls Targeting Russia

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Following Russia’s recognition of breakaway regions in Ukraine and full-scale invasion of the country, authorities in the United States, United Kingdom, European Union, and across the globe imposed a sweeping array of trade...more

Harris Beach PLLC

Federal Financial Regulators Issue Warnings About Russian Sanction Evasion Attempts

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With the imposition of sweeping new sanctions on Russia and Belarus following the invasion of Ukraine, federal financial regulators are issuing warnings about efforts to evade these actions. On Monday, March 7, 2022, the...more

Jones Day

FinCEN Warns Institutions of Sanctions Evasion Risks

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As the U.S. government's economic sanctions against Russia continue to grow, regulators are calling on financial institutions to help detect and prevent attempts to evade these measures through the use of convertible virtual...more

Farrell Fritz, P.C.

If You See Something, Say Something: FinCEN Updates Advisory on Managing Ransomware Attacks

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In a few short weeks, the global loss attributable to cybercrime is expected to surpass $6 trillion.* Therefore, in an effort to protect financial institutions and consumers from further loss, agencies including the United...more

K2 Integrity

Treasury Releases Guidance for the Virtual Currency Industry and Analysis on Ransomware Trends

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Office of Foreign Assets Control (OFAC) released detailed sanctions compliance guidance for the virtual currency industry (the Guidance). The Guidance provides an overview of OFAC sanctions requirements and lists several best...more

K2 Integrity

Proposed Changes to European Union AML/CFT Supervision Regime Signal Major Expansion

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The European Commission, on July 20, 2021, unveiled a landmark legislative proposal that would overhaul the European Union’s approach to anti-money laundering and combatting the financing of terrorism (“AML/CFT”), creating a...more

WilmerHale

Biden: The Fight Against Foreign and Transnational Corruption Is a National Security Interest

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On June 3, 2021, President Biden issued a National Security Memorandum establishing the fight against corruption both at home and abroad as a core United States national security interest and directing the development of a...more

WilmerHale

2021 AML Trends and Developments

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Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more

Foodman CPAs & Advisors

FinCEN Proporciona Una Bienvenida Aclaración a la Sección 314(b)

La Sección 314(b) del Acta Patriota de los EE. UU. (Sec. 314) fue redactada por el Congreso en el 2001 para permitir que las instituciones financieras trabajen con las agencias de aplicación de la ley y entre sí para apoyar...more

Eversheds Sutherland (US) LLP

Congress passes the Anti-Money Laundering Act of 2020, amending and modernizing the Bank Secrecy Act

On January 1, 2021, the US Senate voted to override President Donald Trump’s veto of H.R. 6395, the National Defense Authorization Act for Fiscal Year 2021 (NDAA). As part of the NDAA, the Anti-Money Laundering Act of 2020...more

Latham & Watkins LLP

The Anti-Money Laundering Act of 2020: 5 Key Takeaways

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Expanded compliance obligations will have far-reaching implications for regulated financial institutions and most companies operating in the US. On January 1, 2021, Congress overrode President Trump’s veto and enacted the...more

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