News & Analysis as of

Customer Due Diligence (CDD)

Financial Services Quarterly Report - Fourth Quarter 2017: Developments in the Luxembourg Financial Sector

by Dechert LLP on

Luxembourg recently published two important bills to combat money laundering and terrorism financing – one transposes the EU AML4 Directive1 into Luxembourg law; the second establishes a central register of beneficial owners,...more

AML Regulation and Compliance Trends

by Michael Volkov on

Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

by Foodman CPAs & Advisors on

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more

Will Bankers = Law Enforcers on 5/11/18?

by Foodman CPAs & Advisors on

On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018. The CDD Rule applies to Covered Financial Institutions (federally...more

AML News: FINRA Guidance

In the latest anti-money laundering news, the Financial Industry Regulatory Authority published guidance on AML obligations of firms subject to FINRA supervision. What happened - FINRA’s guidance supplements the...more

May 2018: D-Day for FinCEN Customer Due Diligence and EU’s General Data Privacy Regulations

by Michael Volkov on

Chief compliance officers for financial institutions are going to have a rough May 2018. First, on May 11, 2018, the new CDD Rule for beneficial ownership becomes effective. Two weeks later, on May 25, 2018, the EU’s...more

FINRA Reg Notice 17-40: Is Your AML Program Ready For FinCEN’s CDD Rule?

by Bryan Cave on

On November 21, 2017, FINRA issued Regulatory Notice 17-40 to provide member firms guidance regarding their obligations under FINRA Rule 3310 (Anti-Money Laundering Compliance Program) in light of the Financial Crimes...more

Paradise Papers: The Latest Offshore Leak

by Jones Day on

Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more

Incorporating AML Compliance Into a Compliance Program (Part III of III)

by Michael Volkov on

Global companies should implement an AML program and KYC practices that follow the general outline for best practices, though it does not need to be as rigorous as a financial institution. For most companies, AML risks can...more

Addressing AML Risks in Your Third-Party and Vendor/Supplier Relationships (Part II of III)

by Michael Volkov on

Global companies should incorporate AML risks into their risk analysis of their third-party distributors, agents and other intermediaries. The basic questionnaire, due diligence risk analysis, contractual provisions,...more

Making the Case for Requiring Beneficial Ownership Information

by Michael Volkov on

In this era of aggressive enforcement, global companies have to integrate beneficial ownership requirements when conducting due diligence of business associates and when engaging customers....more

Money Laundering Watchdog Criticizes Lax AML Enforcement and “Creative Compliance” in Wake of Panama Papers

by Ballard Spahr LLP on

PANA Issues Recommendations to European Parliament: Tougher Enforcement, Greater Transparency, Improved Information Sharing and Prohibitions Against Outsourcing of Customer Due Diligence....more

Anti-Money Laundering and Bank Secrecy Act Update

by Moore & Van Allen PLLC on

After the Panama Papers exposed efforts by wealthy individuals and government officials to hide funds offshore, government authorities around the world have responded with new legislation, regulations and enforcement actions...more

AML Beneficial Ownership Register for Irish Funds – Who’s Holding the Baby?

by Dechert LLP on

If you’ve been involved in the funds industry, you will be well aware of the ever-increasing focus on anti-money laundering and “know your customer” requirements by national and supranational regulatory bodies alike. In...more

Anti-Money Laundering and Countering Financing of Terrorism Amendment Act 2017

by DLA Piper on

The Anti-Money Laundering and Countering Financing of Terrorism Amendment Act 2017 (Amendment Act) received Royal assent on 10 August 2017. The Amendment Act makes a number of changes to the Anti-Money Laundering and...more

Fourth Money Laundering Directive (MLD4) and the new Regulations

by Locke Lord LLP on

The MLD4 came into force on 26 June 2017. This was the date by which all member states were required to bring into force the laws, regulations and administrative provisions necessary to facilitate their compliance with...more

FinCEN’s Beneficial Ownership Rule: A Practical Guide to Being Prepared for Implementation

by Ballard Spahr LLP on

In May 2016, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its final rule on Customer Due Diligence (CDD) Requirements for Financial Institutions. ...more

Money Laundering Regulations 2017: government rush threatens a teething period for property auctioneers

by Hogan Lovells on

New money laundering regulations could prove to be a headache for property auctioneers until those affected get to grips with the changes, according to leading figures in the industry....more

Law Enforcement can Follow the Money thanks to the Fifth Pillar of the Final CDD Rule

by Foodman CPAs & Advisors on

Under the Bank Secrecy Act (BSA), the Financial Crimes Enforcement Network (FinCEN) issued a “Fifth Pillar” of the Final Customer Due Diligence (CDD) Rule on May 2016. The covered financial institutions (Banks; Brokers or...more

Fourth Money Laundering Directive (MLD4)

by Locke Lord LLP on

The MLD4 will amend and replace the Third Money Laundering Directive (MLD3) on 26 June 2017. This is the date by which all member states are required to bring into force the laws, regulations and administrative provisions...more

EU Proposes Significant Changes to Anti-Money Laundering Laws

Policy makers in Europe continue to explore responses to the Panama Papers revelations and recent terrorist attacks. On 28 February, European law makers approved important amendments to the EU’s Anti-Money Laundering (AML)...more

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

2016 Year in Review: Money Laundering (Part One)

by Ballard Spahr LLP on

2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

Bankers, Do your US Clients tell you everything that you need to know?

by Foodman CPAs & Advisors on

Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial...more

International AML Enforcement in 2017 Expected to Target Consumer-Due-Diligence Programs, Gaming Entities, Prepaid Cards, Digital...

by K&L Gates LLP on

Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more

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Cybersecurity

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