Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...more
3/6/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
FinCEN ,
Investment Adviser ,
Notice of Proposed Rulemaking (NOPR) ,
NPRM ,
Proposed Rules ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
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
Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership reporting requirements of the Corporate Transparency Act (“CTA”), which...more
The Financial Crimes Enforcement Network (“FinCEN”) recently complied with two important deadlines under the Anti-Money Laundering Act (“AML Act”) — issuing national priorities for AML and countering the financing of...more
First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime -
Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more
Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud?
The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more
9/3/2020
/ Beneficial Owner ,
Borrowers ,
BSA/AML ,
CARES Act ,
Coronavirus/COVID-19 ,
Customer Due Diligence (CDD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Housing Administration (FHA) ,
Final Rules ,
Financial Institutions ,
Financial Regulatory Agencies ,
FinCEN ,
Fraud ,
Government Investigations ,
HUD ,
Lenders ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
SBA ,
U.S. Treasury
“Sanctions Bill from Hell” Targets Real Estate Deals -
On February 13, 2019, Sen. Lindsay Graham (R – S.C.) introduced S.482 – the Defending American Security from Kremlin Aggression Act of 2019 (“DASKAA”), a bill intended...more
3/1/2019
/ Bank Secrecy Act ,
Beneficial Owner ,
Cyber Crimes ,
Economic Sanctions ,
Geographic Targeting Order ,
Legislative Agendas ,
Money Laundering ,
Proposed Legislation ,
Real Estate Investments ,
Real Estate Transactions ,
Russia