In an evolving (and somewhat disjointed) process, FinCEN has been providing guidance to persons and entities that are responsible for filing required beneficial ownership information (“BOI”) reports to FinCEN, as well as to...more
Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more
3/18/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Anti-Money Laundering ,
Beneficial Owner ,
Cash Transactions ,
Compliance ,
Corporate Transparency Act ,
Covered Transactions ,
Financial Crimes ,
FinCEN ,
Geographic Targeting Order ,
Money Laundering ,
Popular ,
Proposed Rules ,
Real Estate Investments ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Reporting Requirements ,
Residential Real Estate Contracts ,
Suspicious Activity Reports (SARs)
Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more
1/8/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Filing Deadlines ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Foreign Corporations ,
Legal Entities ,
NDAA ,
Penalties ,
Publicly-Traded Companies ,
Reporting Requirements
Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more
On March 7, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an alert (the “FinCEN Alert”) urging financial institutions to proactively guard against possible attempts to evade recently implemented sanctions...more
3/10/2022
/ Biden Administration ,
BSA/AML ,
Compliance ,
Economic Sanctions ,
Executive Orders ,
Financial Institutions ,
FinCEN ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
Suspicious Activity Reports (SARs) ,
Ukraine
On November 23, 2021, the Office of the Comptroller of the Currency (the “OCC”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Federal Reserve Board (the “Prudential Regulators”) exercised their collective...more
12/13/2021
/ Bank Service Company Act ,
Banking Sector ,
Banks ,
Compliance ,
Data Breach ,
FDIC ,
Federal Reserve ,
Final Rules ,
Notice Requirements ,
OCC ,
Prudential Regulation Authority (PRA)
On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more
5/23/2019
/ Audits ,
Chief Compliance Officers ,
Compliance ,
Corporate Culture ,
Economic Sanctions ,
Enforcement ,
Federal Sentencing Guidelines ,
Foreign Entities ,
Foreign Financial Institutions (FFI) ,
Internal Controls ,
Interpretive Opinions ,
Jurisdiction ,
Law Enforcement ,
Multinationals ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Risk Management ,
Training
On May 2, 2019, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”)—the U.S. agency tasked with administering and enforcing the U.S.’s economic and trade sanctions programs—published A Framework for...more
5/17/2019
/ Audits ,
Chief Compliance Officers ,
Compliance ,
Corporate Governance ,
Economic Sanctions ,
Enforcement ,
Internal Controls ,
Office of Foreign Assets Control (OFAC) ,
Risk Assessment ,
Training ,
U.S. Treasury