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Request for Comments on FinCEN and SEC rule on CIP

The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

FinCEN Proposes Rule to Target High Risk Residential Real Estate Transfers

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would extend reporting and recordkeeping requirements to persons involved in real estate...more

FinCEN Issues Anti-Money Laundering and Countering the Financing of Terrorism Priorities

FinCEN announces eight areas of focus and advises preparation for issuance of new regulations - On June 30, 2021, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued the first...more

FinCEN Proposes Lower Travel Rule Thresholds for Fiat and Virtual Currencies

In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more

FinCEN Finalizes Customer Due Diligence Requirements for Financial Institutions

On May 11, 2018, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) implemented its Final Rule on Customer Due Diligence Requirements for Financial Institutions (“Rule”) to amend the scope of...more

New York Department of Financial Services Intensifies AML Enforcement Under New Superintendent

Superintendent of New York State Department of Financial Services (“NYDFS”), Maria T. Vullo, has focused the Department’s efforts on enforcement of New York’s Anti-Money Laundering (“AML”) laws. Since her confirmation on June...more

FinCEN Issues Advisory on Jurisdictions with AML/CFT Deficiencies

The Financial Crimes Enforcement Network (“FinCEN”), an agency within the U.S. Treasury Department, has put forth an Advisory on the FATFIdentified Jurisdictions with AML/CFT (Anti-Money Laundering/Combating the Financing of...more

FinCEN Issues Advisory on Cyber Crime

On October 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published an Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime and an accompanying Frequently Asked...more

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