Brace for the possibility of an immediate increase in requests from the Treasury Department’s Financial Crimes Enforcement Network about whether criminal suspects have accounts or have conducted transactions at your firm. Despite industry opposition, FinCEN last week sent a final rule to the Federal Register that will take effect upon publication and expand its 314(a) program to allow local and state law enforcement agencies, and 27 European Union jurisdictions, to make inquiries at your firm. (BD Week, Nov. 30, 2009).
Please see full publication below for more information.