As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities...more
5/13/2020
/ Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
FinCEN ,
Geographic Targeting Order ,
Money Laundering ,
Real Estate Investments ,
Real Estate Market ,
Reporting Requirements ,
Title Insurance ,
Virtual Currency
First in a Two-Post Series -
The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more
2/28/2020
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
Casinos ,
Corruption ,
Critical Infrastructure Sectors ,
Cross-Border Transactions ,
Digital Assets ,
FATF ,
Financial Institutions ,
FinCEN ,
Foreign Correspondent Banking ,
Money Laundering ,
Money Services Business ,
Proposed Rules ,
Real Estate Transactions ,
Rulemaking Process ,
Securities Transactions ,
Strategic Enforcement Plan ,
Terrorism Funding ,
Terrorist Financing Regulations ,
Transparency ,
U.S. Treasury ,
Vulnerable Victims ,
White Collar Crimes
On November 8, 2019, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities used in...more
As we blogged yesterday, the issue of the beneficial ownership of entities and the potentially pernicious role of shell companies in perpetuating money laundering is the primary anti-money laundering (“AML”) concern across...more
11/5/2019
/ Anti-Money Laundering ,
Beneficial Owner ,
Best Practices ,
BSA/AML ,
FATF ,
Financial Institutions ,
Money Laundering ,
New Guidance ,
Risk Assessment ,
Terrorist Financing Regulations ,
Transparency
U.S. House Passes Corporate Transparency Act; FATF Issues Guidance on Identifying Entities’ Beneficial Owners -
First Post in a Two-Post Series on Beneficial Ownership -
As we often blog, the issue of the beneficial...more
11/4/2019
/ Anti-Money Laundering ,
Beneficial Owner ,
Best Practices ,
BSA/AML ,
FATF ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Regulatory Requirements ,
Shell Corporations ,
Transparency
Testimony Supports Bill Requiring States to Collect Beneficial Ownership Information at Entity Formation -
As we have blogged, the proposed Corporate Transparency Act of 2019 (the “Act”) seeks to ensure that persons who...more
5/24/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Structures ,
FATF ,
FBI ,
Financial Regulatory Reform ,
FinCEN ,
Legislative Agendas ,
Limited Liability Company (LLC) ,
Money Laundering ,
OCC ,
Regulatory Burden ,
Regulatory Standards ,
Senate Committees ,
Tax Evasion ,
Transparency
The Financial Crimes Enforcement Network (“FinCEN”) has, once again, extended its Geographic Targeting Order (“GTO”) requiring U.S. title insurance companies to identify the natural persons behind legal entities used in...more