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
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
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
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
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
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
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
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
The Corporate Transparency Act is now poised to take effect on January 1, 2024 (the “Effective Date”), and will immediately impose sweeping new disclosure duties when new entities are formed. During 2024, the other CTA shoe...more
On January 1, 2021, Congress passed the Corporate Transparency Act (“CTA” or the “Act”) to “better enable critical national security, intelligence and law enforcement efforts to counter money laundering, financing of...more
On June 30, 2021, FinCEN announced the first set of government-wide AML/CFT Priorities, as required by the Anti-Money Laundering Act of 2020 ("AML Act"). Consistent with the National Strategy for Combating Terrorist and Other...more
Section 314 of the USA PATRIOT Act (Sec 314) was drafted by Congress in 2001 to allow financial institutions to work with law enforcement agencies and with each other to support the common goal of deterring money laundering...more
U.S. Developments - Federal and State Regulatory Developments - U.S. Department of Homeland Security Issues Challenge for Development of Trusted User Interface for Digital Wallets - The U.S. Department of Homeland Security...more
First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more
On October 25, 2019, FinCEN issued a final rule imposing the Fifth Special Measure against the Islamic Republic of Iran as a “jurisdiction of primary money laundering concern” (“Final Rule”) under Section 311 of the USA...more
Second Post in a Two-Post Series on the ILLICIT CASH Act - A discussion draft of legislation recently introduced in the Senate, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal...more
On June 12, 2019, Kenneth A. Blanco, Director of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), provided remarks at the NYU Law Program on Corporate Compliance and Enforcement that underscored the agency’s...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued guidance on May 9, 2019, underscoring the application of the Bank Secrecy Act (BSA) and its implementing regulations relating to money...more