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FinCEN Renews GTOs

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

FATF Issues Best Practices Guidance on Beneficial Ownership Information

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

Shell Company Update: Congress and FATF Target Beneficial Ownership

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

Joint Statement Issued by Federal Banking Agencies Highlights Importance of Banks’ Risk-Assessments

On July 22, 2019, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency and the U.S....more

Senate Committee Hears from OCC, FinCEN and FBI on Risks Posed by Anonymous Corporate Structures

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

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