On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Federal Register...more
9/11/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
Mortgage Lenders ,
Real Estate Transactions ,
Reporting Requirements ,
Risk Assessment ,
Suspicious Activity Reports (SARs)
The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more
8/5/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Money Laundering ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...more
7/16/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Broker-Dealer ,
BSA/AML ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
NPRM ,
Popular ,
Reporting Requirements ,
Risk Assessment ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations
On April 18, the Internal Revenue Service (“IRS”) issued a draft version of Form 1099-DA, a proposed information reporting form regarding certain digital asset sales and exchanges that “digital asset brokers” will need to...more
4/24/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Cryptocurrency ,
Decentralized Finance (DeFi) ,
Digital Assets ,
Digital Wallets ,
Internal Revenue Code (IRC) ,
IRS ,
Know Your Customers ,
Reporting Requirements
On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more
2/23/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Corporate Transparency Act ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
NPRM ,
Real Estate Investments ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
The beneficial ownership information (“BOI”) registry under the Corporate Transparency Act (“CTA”) is now up and running at the Financial Crimes Enforcement Network (“FinCEN”). This post will follow up on a previous blog...more
The start of calendar year 2024 will bring a new reporting obligation for approximately 32.5 million business organizations. Under the Corporate Transparency Act, covered companies and their senior officers must obtain...more
This week, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial ownership information (“BOI”)...more
12/22/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Gramm-Leach-Blilely Act ,
Money Laundering ,
Popular ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
YouTube
1. What Is the Corporate Transparency Act and Why Was It Enacted? Congress enacted the Corporate Transparency Act (CTA) on January 1, 2021, to address concerns that the inaccessibility of U.S. companies’ beneficial ownership...more
12/5/2023
/ Beneficial Owner ,
Corporate Transparency Act ,
Filing Requirements ,
Financial Crimes ,
Financial Services Industry ,
FinCEN ,
Limited Liability Company (LLC) ,
PCAOB ,
Personal Information ,
Reporting Requirements ,
Subsidiaries ,
Tax Exemptions ,
Trustees
The Financial Crimes Enforcement Network (“FinCEN”) has extended the deadline for reporting beneficial ownership information (“BOI”) under the Corporate Transparency Act (“CTA”) for reporting companies formed in 2024. ...more
On November 16, the Financial Crimes Enforcement Network (“FinCEN”) issued – again –expanded FAQs pertaining to beneficial ownership information (“BOI”) reportable under the Corporate Transparency Act (“CTA”). These expanded...more
11/17/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Financial Crimes ,
FinCEN ,
Lenders ,
Mortgage Lenders ,
Popular ,
Proposed Legislation ,
Reporting Requirements
Beginning on January 1, 2024, many U.S. legal entities and foreign entities registered to do business in the U.S. will be required to report information about themselves, their beneficial owners, and their company applicants...more
10/26/2023
/ Acquisitions ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Business Ownership ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Filing Requirements ,
Financial Institutions ,
FinCEN ,
Legal Entities ,
Popular ,
Reporting Requirements ,
Securities Exchange Act of 1934
The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more
10/9/2023
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Corporate Transparency Act ,
Department of Justice (DOJ) ,
Financial Crimes ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Notice of Proposed Rulemaking (NOPR) ,
Office of Foreign Assets Control (OFAC) ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs) ,
Whistleblowers
The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”). They pertain, in part, to a proposed extension of the filing deadline for certain...more
10/2/2023
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Comment Period ,
Corporate Transparency Act ,
Filing Deadlines ,
Financial Crimes ,
Financial Regulatory Reform ,
FinCEN ,
National Security ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements
The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as...more
On March 24, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a press release and published initial guidance to assist the public in understanding the beneficial ownership information (BOI) reporting...more
Form Repeatedly Invites Response of “Unknown” As to Critical Information -
The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice and request for comment (“Notice”) on the proposed form to collect and...more
After reviewing how the AMLA expands the BSA’s goals, we look at which AMLA provisions have the most impact on BSA compliance, including the AMLA’s emphasis on information sharing, the Financial Crimes Enforcement Network’s...more
Summary -
On September 30, 2022, the Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of Treasury, issued its final rule, Beneficial Ownership Information Reporting Requirements (Final Rule),...more
Second Post in a Two-Post Series on the CTA Implementing Regulations -
As we just blogged, the Financial Crimes Enforcement Network (“FinCEN”) has issued a final rule (“Final Rule”) regarding the beneficial ownership...more
First Post in a Two-Post Series on the CTA Implementing Regulations -
On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued its final rule, Beneficial Ownership Information Reporting...more
As we initially blogged, the Financial Crimes Enforcement Network (“FinCEN”) issued on December 7 a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership (“BO”) reporting requirements of the Corporate...more
On December 3, the U.S. House and Senate Armed Services Committees reached an agreement on the National Defense Authorization Act (“NDAA”), an annual defense spending bill. Within this huge bill (well over 4,500 pages) are...more
Federal Register Notice Implicates Debate Over BSA Reporting Burden -
As we have blogged, the Financial Crimes Enforcement Network (“FinCEN”) consistently has stressed the importance of Suspicious Activity Reports (“SARs”)...more
ABA Tax Fraud Panel to Discuss IRS CI and Crypto Criminals -
The Internal Revenue Service – Criminal Investigation (IRS CI) has made it clear that it is focusing on the abuse of digital currencies to further tax evasion,...more
12/10/2019
/ Bitcoin ,
Capital Gains ,
Child Pornography ,
Corruption ,
Criminal Investigations ,
Cryptocurrency ,
Cyber Crimes ,
Dark Web ,
Data-Sharing ,
Digital Currency ,
Digital Wallets ,
Enforcement Actions ,
Exploitation ,
Extradition ,
Financial Crimes ,
Income Taxes ,
Indictments ,
IRS ,
Money Laundering ,
OECD ,
Popular ,
Reporting Requirements ,
Tax Evasion ,
Virtual Currency