The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more
9/19/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
BSA/AML ,
Compliance ,
Compliance Dates ,
Data-Sharing ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
Investment Funds ,
Patriot Act ,
Suspicious Activity Reports (SARs)
Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more
9/19/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
Compliance ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
FinCEN ,
Internal Controls ,
Patriot Act ,
Policies and Procedures ,
Proposed Amendments ,
Proposed Rules ,
Risk Assessment
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Residential Real Estate Rule) requiring certain persons involved in residential real estate closings and...more
9/19/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Cash Transactions ,
Compliance ,
FinCEN ,
Geographic Targeting Order ,
Real Estate Transactions ,
Real Estate Transfers ,
Reporting Requirements ,
Residential Property Owners ,
U.S. Treasury
On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a...more
The Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Treasury Department, has issued a proposed rule (the “Proposal”) that would subject certain investment advisers to anti-money laundering (“AML”)...more
2/19/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Financial Institutions ,
Financial Transactions ,
FinCEN ,
Investment Adviser ,
Proposed Rules ,
Recordkeeping Requirements ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
In This Issue. The U.S. Securities and Exchange Commission (SEC) voted to propose money market fund reforms; the SEC also proposed amendments to Rule 10b5-1 trading plans and to modernize and improve share repurchase...more
12/17/2021
/ 10b5-1 Plans ,
AML/CFT ,
Bank Secrecy Act ,
Banking Sector ,
Chief Compliance Officers ,
Comment Period ,
Community Reinvestment Act ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Electronic Fund Transfer Act ,
Federal Reserve ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Insider Trading ,
Investment Company Act of 1940 ,
Investment Funds ,
Money Market Funds ,
OCC ,
Policies and Procedures ,
Proposed Amendments ,
Proposed Rules ,
Public Comment ,
Regulation E ,
Regulatory Agenda ,
Reporting Requirements ,
Request For Information ,
Risk Management ,
Rule 2a-7 ,
Rulemaking Process ,
SBS Entities ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Security-Based Swaps ,
Stock Repurchases ,
Swap Dealers ,
Trading Plans
In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more
12/10/2021
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Amended Rules ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Beneficial Owner ,
Broker-Dealer ,
BSA/AML ,
CFTC ,
Comment Period ,
Continuing Education ,
Coronavirus/COVID-19 ,
Corporate Transparency Act ,
FDIC ,
FFIEC ,
Final Rules ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Services Industry ,
FinCEN ,
Foreign Corporations ,
Libor ,
Notice of Proposed Rulemaking (NOPR) ,
OCC ,
Proposed Rules ,
Public Comment ,
Real Estate Transactions ,
Recordkeeping Requirements ,
Registration Requirement ,
Regulation Z ,
Reporting Requirements ,
Secured Overnight Funding Rate (SOFR) ,
Securities and Exchange Commission (SEC)
In This Issue. Federal agencies issued a joint statement regarding an orderly transition away from the London Interbank Offered Rate (LIBOR); the Office of the Comptroller of the Currency (OCC) issued an updated...more
10/22/2021
/ Bank Secrecy Act ,
Banking Sector ,
CFTC ,
Comment Period ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Threats ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Environmental Social & Governance (ESG) ,
Financial Services Industry ,
FinCEN ,
Investors ,
Joint Statements ,
Libor ,
OCC ,
Proposed Rules ,
Public Comment ,
Ransomware ,
Secured Overnight Funding Rate (SOFR) ,
Suspicious Activity Reports (SARs)
In This Issue. The U.S. Securities and Exchange Commission (SEC) adopted amendments to modernize filing fee disclosure and payment methods; the Financial Industry Regulatory Authority (FINRA) announced an examination of...more
10/15/2021
/ Anti-Money Laundering ,
Automated Clearing House (ACH) ,
Bank Secrecy Act ,
Broker-Dealer ,
BSA/AML ,
Disclosure Requirements ,
Filing Fees ,
Financial Industry Regulatory Authority (FINRA) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Companies ,
Investors ,
Payment Methods ,
Securities and Exchange Commission (SEC) ,
Special Purpose Acquisition Companies (SPACs) ,
Terrorism Funding
FinCEN has proposed extending its anti-money laundering (AML) program requirement for banks to banks that are not subject to regulation by a federal functional regulator, including state chartered limited purpose trust...more
9/1/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
BSA/AML ,
CIP ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
FinCEN ,
Money Laundering ,
Patriot Act ,
Proposed Regulation ,
Public Comment ,
Reporting Requirements ,
Suspicious Activity Reports (SARs)
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has expanded the due diligence obligations of certain financial institutions that are subject to a customer identification program requirement under...more
5/20/2016
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banks ,
Beneficial Owner ,
Customer Identification Program (CIP) ,
Due Diligence ,
Final Rules ,
Financial Institutions ,
FinCEN ,
Legal Entities ,
Recordkeeping Requirements ,
Verification Requirements
The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more
8/31/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
BSA/AML ,
CIP ,
Comment Period ,
Cross-Border Transactions ,
Currency Transaction Reports (CTR) ,
Financial Institutions ,
FinCEN ,
Information Sharing ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Money Laundering ,
Patriot Act ,
Proposed Regulation ,
Recordkeeping Requirements ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
Training Requirements
Regulatory Developments -
CFTC Provides No-Action Relief from Introducing Broker and Commodity Trading Advisor Registration to Non-U.S. Persons Who Advise on or Facilitate Swaps Transactions for Certain International...more
6/18/2015
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Brokers ,
CFTC ,
Civil Monetary Penalty ,
Community Banks ,
Enforcement ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
FinCEN ,
Investment Adviser ,
No-Action Letters ,
No-Action Relief ,
Reporting Requirements ,
Swap Dealers ,
Swaps
The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has proposed revisions (the “Proposal”) to its rules implementing the Bank Secrecy Act (the “BSA”) that would spell out specific anti-money...more