On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules to modernize and improve financial institutions’ anti-money laundering and countering the financing...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more
One of the hottest topics in the HOA-world over the past year has been the implementation of the Corporate Transparency Act (CTA). Although enacted by Congress in 2021, registrations under the CTA became mandatory for newly...more
The new Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing (“AMLR”) extended for the first time the scope of application of anti-money...more
On May 30, 2024, following passage by the European Parliament in late April, the European Council officially adopted a set of rules that modernizes and harmonizes money laundering and terrorist financing (“AML/CFT”)...more
On May 13, the US Securities and Exchange Commission (SEC) and the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) jointly released a notice of proposed rulemaking (NPRM) which, if...more
There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more
The Federal Decree-Law No. 14/2018 on the Central Bank and the Organisation of Financial Institutions and Activities, along with its recent amendments outlined in Federal Decree-Law No. 54/2023, has introduced significant...more
In recent years, the UAE has taken significant steps to enhance transparency and combat financial crimes within its business landscape. Central to these efforts is the identification and regulation of Ultimate Beneficial...more
When is a US Taxpayer required to disclose offshore accounts on an FBAR and IRS Form 8938? While many US taxpayers and expatriates have come to understand the requirements of the FinCEN Form 114 or FBAR, a surprising number...more
On February 22, 2024, Frankfurt won the joint vote to host EU’s central enforcer in the fight against financial crime. The new Authority for Anti-Money Laundering and Countering the Financing of Terrorism (“AMLA”) will...more
If you are operating a small business and have not educated yourself about the Corporate Transparency Act (“CTA”) requirements that became effective on January 1, 2024, now would be a good time to pay attention. Knowing the...more
The Corporate Transparency Act was passed by Congress with bipartisan support in 2021 and went into effect on January 1, 2024. Broadly speaking, the law requires private companies to file a report with the Department of...more
On January 17, 2024, the Council of the European Union (Council) and the European Parliament (Parliament) announced that a political agreement had been reached on (i) a new Regulation setting forth a single anti-money...more
The Corporate Transparency Act (the “CTA”) is a new federal law enacted in 2021 to combat money laundering, terrorism, tax fraud and other illegal activities. Starting January 1, 2024, the CTA will require a substantial...more
The Cayman Islands recently received an early Holiday gift when the EU Commission published a regulation in mid-December paving the way to remove Cayman from its list of ‘high-risk’ countries for AML/CFT purposes. The...more
Beginning January 1, 2024, most small businesses in the United States will have to report information about the people who own and control the business to the federal government. This new reporting rule was established by...more
As we approach year-end, we wanted to remind you about the upcoming implementation of the Corporate Transparency Act ("CTA"), which is set to take effect on January 1, 2024. The CTA will impose significant new reporting...more
A new regulation under the federal Corporate Transparency Act (CTA) that, for the first time, will require disclosure of information about all U.S. formed corporations, limited liability companies, and limited partnerships...more
The October 7, 2023 attacks on Israel by Hamas have re-focused U.S. government efforts to identify and counter funding streams for Hamas and terrorist activity in general – including, in particular, through the use of...more
This Note is the second part of our look at regulatory expectations for sanctions compliance in the U.K. The first part of our review looked at Financial Conduct Authority (“FCA”) systems and controls requirements. The focus...more
The federal Corporate Transparency Act will apply to all domestic entities, including corporations, limited liability companies and limited partnership effective January 1, 2024. Effective January 1, 2024, the federal...more
The Financial Action Task Force ("FATF") is the global standard-setter on anti-money laundering ("AML"), countering terrorist financing ("CFT") and counter proliferation financing. FATF's standards, also referred to as...more
Trade-based money laundering (TBML) describes a set of techniques through which drug traffickers, terrorists and other criminals use the veneer of trade to move illicit funds across borders while disguising the origin and...more
The Corporate Transparency Act (CTA), enacted by Congress as part of the Anti-Money Laundering Act of 2020, for the first time under federal law, requires the establishment of a centralized, national beneficial ownership...more