Summary -
On September 30, 2022, the Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of Treasury, issued its final rule, Beneficial Ownership Information Reporting Requirements (Final Rule),...more
Second Post in a Two-Post Series on the CTA Implementing Regulations -
As we just blogged, the Financial Crimes Enforcement Network (“FinCEN”) has issued a final rule (“Final Rule”) regarding the beneficial ownership...more
First Post in a Two-Post Series on the CTA Implementing Regulations -
On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued its final rule, Beneficial Ownership Information Reporting...more
As we initially blogged, the Financial Crimes Enforcement Network (“FinCEN”) issued on December 7 a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership (“BO”) reporting requirements of the Corporate...more
Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership reporting requirements of the Corporate Transparency Act (“CTA”), which...more
The Financial Crimes Enforcement Network (“FinCEN”) recently complied with two important deadlines under the Anti-Money Laundering Act (“AML Act”) — issuing national priorities for AML and countering the financing of...more
First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more
Testimony Supports Bill Requiring States to Collect Beneficial Ownership Information at Entity Formation -
As we have blogged, the proposed Corporate Transparency Act of 2019 (the “Act”) seeks to ensure that persons who...more
5/24/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Structures ,
FATF ,
FBI ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Limited Liability Company (LLC) ,
Money Laundering ,
OCC ,
Regulatory Burden ,
Regulatory Standards ,
Senate Committees ,
Tax Evasion ,
Transparency
In early March, the House Financial Services Committee released three proposed bills to codify many of the suggested reforms discussed during ongoing conversation among financial agencies, law enforcement, financial...more
3/29/2019
/ AML/CFT ,
Beneficial Owner ,
BSA/AML ,
Financial Crimes ,
Financial Regulatory Reform ,
Financial Services Committee ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Reporting Requirements ,
Shell Corporations ,
Transparency ,
White Collar Crimes
FinCEN Cites Low Risk of Money Laundering and High Regulatory Burden of Rule -
On September 7, 2018, the Financial Crimes Enforcement Network (“FinCEN”) issued permanent exceptive relief (“Relief”) to the Beneficial...more
9/17/2018
/ Bank Secrecy Act ,
Beneficial Owner ,
Consumer Financial Products ,
Due Diligence ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Know Your Customers ,
Money Laundering ,
Regulatory Burden ,
Regulatory Oversight ,
Regulatory Requirements ,
Reporting Requirements
Last year, we posted FinCEN’s Beneficial Ownership Rule: A Practical Guide to Being Prepared for Implementation regarding the Customer Due Diligence Requirements for Financial Institutions Rule (the “Beneficial Ownership...more
On September 15th, FinCEN issued its latest “Advisory on FATF-Identified Jurisdictions with AML/CTF Deficiencies.” The FATF, or the Financial Action Task Force, is a 37-member intergovernmental body, including the United...more
9/20/2017
/ AML/CFT ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Due Diligence ,
FATF ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Regulatory Standards ,
Risk Management ,
Terrorist Financing
In May 2016, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its final rule on Customer Due Diligence (CDD) Requirements for Financial Institutions. ...more
FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more
8/5/2016
/ Banking Sector ,
Beneficial Owner ,
Cash Transactions ,
Covered Transactions ,
FinCEN ,
Geographic Targeting Order ,
Insurance Industry ,
Money Laundering ,
Real Estate Investments ,
Real Estate Market ,
Reporting Requirements ,
Title Insurance
As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more
5/11/2016
/ Bad Actors ,
Bank Holding Company Act ,
Beneficial Owner ,
Covered Financial Institutions ,
Due Diligence ,
Financial Institutions ,
FinCEN ,
IRS ,
Limited Liability Company (LLC) ,
Panama Papers ,
Reporting Requirements ,
Tax Evasion