The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on March 11, 2025, issued a Geographic Targeting Order (the Southwest GTO) as part of a "whole-of-government approach" to leverage all...more
3/14/2025
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cartels ,
Executive Orders ,
Financial Services Industry ,
FinCEN ,
Geographic Targeting Order ,
Human Trafficking ,
Money Laundering ,
Reporting Requirements ,
Significant Transnational Criminal Organization ,
Trump Administration ,
U.S. Treasury
The Corporate Transparency Act (CTA) requires "Reporting Companies" – domestic entities created by the filing of a document with a secretary of state and non-U.S. entities that have registered to do business in the United...more
12/6/2024
/ Beneficial Owner ,
Business Entities ,
Commerce Clause ,
Constitutional Challenges ,
Corporate Transparency Act ,
Financial Crimes ,
FinCEN ,
National Security ,
Preliminary Injunctions ,
Regulatory Requirements ,
Reporting Requirements ,
Tenth Amendment
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
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 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
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