On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule under the Bank Secrecy Act (“BSA”) requiring certain persons involved in real estate closings and settlements to report and maintain...more
9/12/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Exemptions ,
Final Rules ,
FinCEN ,
Noncompliance ,
Penalties ,
Popular ,
Proposed Rules ,
Real Estate Transfers ,
Recordkeeping Requirements ,
Settlement
On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would extend reporting and recordkeeping requirements to persons involved in real estate...more
The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector -
Regulators have long considered the lack of anti-money...more
2/27/2024
/ AML/CFT ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Compliance ,
Currency Transaction Reports (CTR) ,
Customer Due Diligence (CDD) ,
Exempt Reporting Advisers (ERAs) ,
FinCEN ,
Internal Revenue Code (IRC) ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Law Enforcement ,
Patriot Act ,
Policies and Procedures ,
Proposed Rules ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Third-Party Service Provider
After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules
On January 14, in a surprise move,...more
1/18/2021
/ Administrative Procedure Act ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Biden Administration ,
Cryptocurrency ,
Financial Institutions ,
FinCEN ,
Notice of Proposed Rulemaking (NOPR) ,
Popular ,
Proposed Rules ,
Public Comment ,
Recordkeeping Requirements ,
Reporting Requirements ,
Travel Rule ,
U.S. Treasury ,
Uniform Commercial Code (UCC) ,
Virtual Currency
In October of last year, we wrote about the challenges faced by virtual currency businesses in complying with the Travel Rule following new guidance from the Financial Action Task Force (FATF) and the Financial Crimes...more
11/5/2020
/ Bank Secrecy Act ,
Compliance ,
Cryptocurrency ,
Department of Justice (DOJ) ,
FATF ,
Federal Reserve ,
Financial Institutions ,
FinCEN ,
Proposed Rules ,
Suspicious Activity Reports (SARs) ,
Travel Rule ,
Uniform Commercial Code (UCC) ,
Virtual Currency ,
Wire Transfers