The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more
9/6/2024
/ AML/CFT ,
Bank Secrecy Act ,
Biden Administration ,
Compliance ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Institutions ,
FinCEN ,
NPRM ,
Popular ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...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
7/15/2024
/ AML/CFT ,
Anti-Money Laundering ,
Board of Directors ,
Compliance ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Oversight Committee ,
Proposed Rules ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Terrorism Funding
Nearly six months after President Joe Biden signed an executive order (EO) authorizing secondary sanctions against Foreign Financial Institutions (FFIs) conducting or facilitating significant transactions with certain...more
6/25/2024
/ Biden Administration ,
Compliance ,
Economic Sanctions ,
Evasion ,
Executive Orders ,
Financial Transactions ,
Foreign Financial Institutions (FFI) ,
Foreign Policy ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
U.S. Treasury
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) amended the Cuban Assets Control Regulations (CACR), 31 CFR Part 515, to promote internet freedom in Cuba, support independent Cuban private-sector...more
5/30/2024
/ Amended Regulation ,
Bank Accounts ,
Banking Sector ,
Biden Administration ,
Blocked Person ,
Cuba ,
Cuban Assets Control Regulations (CACR) ,
Economic Development ,
Entrepreneurs ,
Financial Services Industry ,
Foreign Nationals ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Private Sector ,
SDN List
The Corporate Transparency Act (CTA) is the gift that keeps giving. As affected entities and their advisers struggle to determine whether they are subject to the beneficial ownership information (BOI) reporting provisions of...more
4/30/2024
/ Beneficial Owner ,
Constitutional Challenges ,
Corporate Counsel ,
Corporate Entities ,
Corporate Governance ,
Corporate Transparency Act ,
Criminal Code ,
Department of Justice (DOJ) ,
Fifth Amendment ,
FinCEN ,
Fourth Amendment ,
Homeowners Association (HOA) ,
Penalties ,
Proposed Legislation ,
Reporting Requirements ,
Small Business ,
Trusts ,
U.S. Treasury
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued General License 44A (GL 44A) on April 17, 2024, replacing and superseding General License 44 (GL 44). On Oct. 18, 2023, OFAC suspended...more
Please join Holland & Knight's Financial Services Regulatory Team for a roundtable discussion on what to expect on the financial services landscape in 2024. Our attorneys will present on a wide range of topics in a "3-Minute...more
1/3/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Continuing Legal Education ,
Federal Trade Commission (FTC) ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Regulatory Agencies ,
Financial Services Industry ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Securities and Exchange Commission (SEC) ,
Webinars
The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) on Oct. 18, 2023, suspended certain U.S. sanctions under the Venezuela Sanctions Regulations (VSR), including measures on Venezuela's oil and gas...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a final rule on Sept. 29, 2022, implementing the beneficial ownership information (BOI) reporting requirement of the Corporate...more
10/7/2022
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Officers ,
Directors ,
Domestic Corporations ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Foreign Corporations ,
Reporting Requirements ,
Securities Exchange Act ,
U.S. Treasury
Today the federal bank regulatory agencies issued joint guidance on Providing Financial Services to Customers Engaged in Hemp-Related Businesses (Joint Hemp Guidance). These agencies – the Office of the Comptroller of the...more
12/4/2019
/ Banking Sector ,
Commodities ,
Controlled Substances Act ,
Farm Bill ,
FDIC ,
Federal Reserve ,
FinCEN ,
Food and Drug Administration (FDA) ,
Hemp ,
Joint Statements ,
OCC ,
Regulatory Authority ,
Regulatory Standards ,
SAR ,
USDA
• President Donald Trump has issued an Executive Order expanding the current sanctions relating to Venezuela by blocking all property and interests in property of the government of Venezuela and the Nicolás Maduro...more
8/8/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Foreign Policy ,
General Licenses ,
Human Rights ,
Humanitarian Assistance ,
Office of Foreign Assets Control (OFAC) ,
Politically Exposed Person (PEPs) ,
SDN List ,
Secretary of the Treasury ,
Trump Administration ,
Venezuela
• National Security Advisor Ambassador John Bolton issued a statement threatening sanctions against non-U.S. banks for facilitating illegitimate transactions with certain Venezuelan individuals and entities.
• This...more
3/14/2019
/ Banking Sector ,
Blocked Entities ,
Cross-Border Transactions ,
Economic Sanctions ,
Executive Orders ,
Foreign Financial Institutions (FFI) ,
Foreign Relations ,
Office of Foreign Assets Control (OFAC) ,
SDN List ,
Secondary Sanctions ,
Venezuela
• The U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) has designated five officials affiliated with the regime of Nicolas Maduro pursuant to Executive Order 13850 (E.O. 13850), including...more
• Pursuant to Executive Order 13850 (E.O. 13850), the U.S. Department of the Treasury's (Treasury) Office of Foreign Assets Control (OFAC) designated Petroleos de Venezuela, S.A. (PdVSA), effectively blocking PdVSA's property...more
1/31/2019
/ Banking Sector ,
Blocked Person ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Oil & Gas ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela
• President Donald Trump has issued an Executive Order (the E.O.) imposing additional sanctions with respect to the situation in Venezuela, and the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) has...more
8/29/2017
/ Blocked Person ,
Citgo ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Petroleum ,
SDN List ,
Trump Administration ,
Venezuela
The Financial Crimes Enforcement Network (FinCEN) on Aug. 25, 2016, issued a notice of proposed rulemaking (Proposed Rule) to implement Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools...more
8/29/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Banks ,
BSA/AML ,
Financial Institutions ,
FinCEN ,
Non-Resident Aliens ,
Puerto Rico ,
Regulatory Standards ,
Virgin Islands
In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more
5/20/2016
/ Bank Accounts ,
Banking Sector ,
Beneficial Owner ,
BSA/AML ,
Corporate Counsel ,
Corruption ,
Criminal Investigations ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
Economic Sanctions ,
FATCA ,
Financial Institutions ,
FinCEN ,
Foreign-Owned Corporations ,
Geographic Targeting Order ,
IRS ,
Money Laundering ,
Mossack Fonseca ,
Office of Foreign Assets Control (OFAC) ,
Offshore Funds ,
Panama Papers ,
Shell Corporations ,
Tax Evasion ,
Tax Haven ,
Wire Transfers
On April 21, 2015 – after months of speculation by those in the Bank Secrecy Act/anti-money laundering compliance community – the Financial Crimes Enforcement Network (FinCEN) issued a Geographic Targeting Order (GTO) in...more
August was a busy month for the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). Among other initiatives, FinCEN issued its long-awaited proposed regulations on customer due diligence (CDD)...more
9/4/2014
/ Advisory Opinions ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Compliance ,
Cross-Border Transactions ,
Due Diligence ,
Enforcement Actions ,
FATF ,
Financial Institutions ,
FinCEN ,
Mexico ,
Proposed Regulation ,
Rulemaking Process
On Aug. 11, 2014, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued FIN-2014-A007 (the "Advisory"). Among other things, the Advisory highlights the importance of maintaining a strong...more