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)
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
The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of the Treasury, issued guidance on February 14, 2014 (the “Cannabis Guidance”), to clarify Bank Secrecy Act expectations for financial...more
Even though as part of his confirmation hearings Attorney General Sessions informally indicated that enforcement of the federal criminal laws for marijuana businesses would not be a priority, this last week the Trump...more
On May 11, 2016, FinCEN published in the Federal Register its long-awaited anti-money laundering (“AML”) rules (the “Final Rules”) governing corporate entities doing business with banks and other financial institutions that...more
6/8/2016
/ Anti-Money Laundering ,
Banking Sector ,
Beneficial Owner ,
Covered Financial Institutions ,
Customer Due Diligence (CDD) ,
Exceptions ,
Exemptions ,
Final Rules ,
FinCEN ,
Legal Entities ,
Lenders ,
Penalties ,
Recordkeeping Requirements ,
Suspicious Activity Reports (SARs)