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U.S. Treasury AML/CFT

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

Dechert LLP

Treasury Issues Final Investment Advisers AML/CFT Program Rule

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Treasury issued a final rule requiring certain investment advisers to establish an AML/CFT Program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Final Rule). The Final Rule applies to...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

Ballard Spahr LLP

Three Members of Congress and U.S. Treasury Express Concerns that Florida Law Prohibiting Banks from Considering Customers’...

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As we previously blogged, a Florida law (Fla. Stat. § 655.0323, entitled “Unsafe and unsound practices”) which became effective July 1, 2024 prohibits federal and state depository institutions conducting business in the state...more

Troutman Pepper

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

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As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Morrison & Foerster LLP

FinCEN & the SEC: Will the Real RIA and ERA Customers Please Stand Up?

On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more

Troutman Pepper

FinCEN Proposes Rule to Strengthen AML/CFT Programs

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On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Ballard Spahr LLP

Treasury Issues RFI on Use of AI in Financial Services

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After several years of monitoring and reporting on artificial intelligence (AI) in financial services, the U.S. Department of Treasury (Treasury) has embarked on initial rulemaking efforts and issued a request for information...more

Ballard Spahr LLP

Treasury Issues Request for Information on Use of AI in Financial Services

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The U.S. Department of the Treasury (“Treasury”) has released a Request for Information on the Uses, Opportunities, and Risks of Artificial Intelligence (“AI”) in the Financial Services Sector (“RFI”).  Written comments are...more

Eversheds Sutherland (US) LLP

FinCEN and SEC propose Customer Identification Program requirements for investment advisers

Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

Ballard Spahr LLP

Treasury Issues Broad National Strategy for Combatting Illicit Financing

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Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more

Akin Gump Strauss Hauer & Feld LLP

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

In February 2024, the U.S. Department of the Treasury issued its 2024 Investment Adviser Risk Assessment, which explains that there are “several illicit finance threats involving investment advisers,” including that...more

Paul Hastings LLP

Daily Financial Regulation Update -- Friday, April 5, 2024

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April 4, 2024- Secretary of the Treasury Janet L. Yellen held a roundtable discussion with representatives from the American, European, and Japanese business communities and other experts to discuss business conditions in...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

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 3

Editor's Note: The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically...more

ArentFox Schiff

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

ArentFox Schiff on

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

Foodman CPAs & Advisors

Acciones Clave GAFI Febrero 2024

El 02/23/24, el Grupo de Acción Financiera Internacional (GAFI o “FATF”), una entidad intergubernamental independiente que desarrolla políticas para la protección de nuestro sistema financiero global contra el lavado de...more

Foodman CPAs & Advisors

FATF Key Actions February 2024

On 2/23/24, the Financial Action Task Force (FATF), an independent inter-governmental entity that develops policies for protection of our global financial system from money laundering, terrorist financing and financing of...more

Sherman & Howard L.L.C.

Alphabet Soup: FinCEN Proposal Would Add AML/CFT Obligations Under the BSA for RIAs & ERAs

Let me start by translating that headline to English. On February 15, 2024, the Financial Crimes Enforcement Network (FinCEN) division of the Department of Treasury issued a rule proposal that would require investment...more

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more

Morrison & Foerster LLP

FinCEN: Eyes on Investment Advisers

In July 2020, a sensitive Federal Bureau of Investigation (FBI) document was leaked to the public. The document outlined the FBI’s suspicions that the private investment funds industry was providing choice money laundering...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

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On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - February 2024 - 2

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

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On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

White & Case LLP

FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs

White & Case LLP on

On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more

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