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Customer Due Diligence (CDD) Financial Crimes

K2 Integrity

Pending FinCEN Investment Adviser Rule: Industry Perspective On Next Steps You Should Be Taking

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On 22 August 2024, K2 Integrity hosted a webinar discussing considerations related to the pending anti-money laundering rule (AML) for investment advisers (IAs) from the Financial Crimes Enforcement Network (FinCEN). The...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

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The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

Ballard Spahr LLP

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

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The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...more

Troutman Pepper

FinCEN Proposes Rule to Strengthen AML/CFT Programs

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On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Ballard Spahr LLP

FinCEN Releases Updated BOI FAQs

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On April 18, the Financial Crimes Enforcement Network (“FinCEN”) released updated FAQs related to the Corporate Transparency Act (“CTA”) and Beneficial Ownership Information (“BOI”) Rule. The last round of updates occurred in...more

Ballard Spahr LLP

FATF Re-Rates United States as “Largely Compliant” with Beneficial Ownership Recommendation

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The Financial Action Task Force (“FATF”) has re-rated the U.S. as “largely compliant” with FATF’s Recommendation 24, which pertains to transparency related to beneficial ownership of legal persons. Specifically, FATF...more

Ballard Spahr LLP

The CTA at Two Months: Key Updates and Action Items

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After years of anticipation, the Corporate Transparency Act (the CTA) officially went into effect on January 1, 2024. Now that we are two months into the CTA era, below are a few updates and recommended action items based on...more

Cadwalader, Wickersham & Taft LLP

FinCEN Proposes New Rule Requiring AML Compliance Programs for Investment Advisers

On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more

Paul Hastings LLP

FinCEN Proposes AML and SAR Filing Obligations for RIAs and ERAs

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On February 13, 2024, the United States Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would apply comprehensive anti-money laundering and countering the financing of terrorism...more

Morrison & Foerster LLP

The Corporate Transparency Act: Access Rules

On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued final rules establishing a framework for accessing, using, and protecting beneficial ownership information (BOI)...more

Holland & Knight LLP

The Corporate Transparency Act: FinCEN Clarifies the Subsidiary Rule Exemption

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The Corporate Transparency Act (CTA) entered into force on Jan. 1, 2024. Under the beneficial ownership information reporting rule of the CTA, certain entities – such as corporations, limited liability companies and other...more

Stark & Stark

The Corporate Transparency Act and Reporting Requirements

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On January 1, 2024, the Corporate Transparency Act, 33 U.S.C. §5336, (the “CTA”) took effect and strict compliance must be met by all entities and individuals to which it applies. The CTA adds reporting requirements for...more

Williams Mullen

Reminder: The Corporate Transparency Act (CTA) goes into effect on Monday, January 1, 2024

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The purpose of this memo is to provide our clients with an overview of the Corporate Transparency Act (CTA) and steps necessary to take to be compliant with the CTA. The CTA was enacted into law on January 1, 2021 as part...more

Troutman Pepper

Federal Agencies Issue Access Rule to Beneficial Ownership Information Pursuant to the CTA

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On December 21, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Financial Crimes Enforcement Network (FinCen), the National Credit Union Administration, along with...more

Ballard Spahr LLP

FinCEN Issues Final CTA BOI Access Rules, Heralded by YouTube Video

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This week, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial ownership information (“BOI”)...more

Jenner & Block

[Webinar] When Worlds Collide: Navigating Competing Financial Crime and Consumer Protection Requirements - January 17th, 3:30 pm -...

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In the Trenches: Lessons for Bank-Fintech Partnerships – Webinar Series - Join us for this three-part series examining issues, tips, and the legal state of play for bank-fintech partnerships. Each session will be a...more

Ballard Spahr LLP

FinCEN Extends CTA Reporting Deadline for New Companies from 30 to 90 Days

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The Financial Crimes Enforcement Network (“FinCEN”) has extended the deadline for reporting beneficial ownership information (“BOI”) under the Corporate Transparency Act (“CTA”) for reporting companies formed in 2024. ...more

Ballard Spahr LLP

FinCEN Expands CTA FAQs

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On November 16, the Financial Crimes Enforcement Network (“FinCEN”) issued – again –expanded FAQs pertaining to beneficial ownership information (“BOI”) reportable under the Corporate Transparency Act (“CTA”).  These expanded...more

Orrick, Herrington & Sutcliffe LLP

CSBS says state regulators need access to FinCEN’s beneficial ownership database

On February 14, the Conference of State Bank Supervisors commented that FinCEN should be more explicit in its inclusion of state regulators as agencies that can request access to FinCEN’s forthcoming secure, non-public...more

Davis Wright Tremaine LLP

FinCEN Beneficial Ownership Information Access Proposal Raises Many Questions

As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more

Hogan Lovells

FCA’s review into challenger banks uncovers deficiencies in financial crime controls

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In recent years, the financial services industry has seen an exponential growth in the popularity of challenger banks in the UK. Digitally-driven, technologically innovative and efficient onboarding processes are some of the...more

BCLP

FCA’s thinly veiled warning to challenger and traditional retail banks over financial crime risk

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On 22 April 2022, the FCA published the findings of its review of financial crime controls at six relatively new and primarily digital challenger banks that all offer similar products to traditional retail banks. These six...more

Troutman Pepper

Financial Crimes Enforcement Network Makes Ransomware a Priority

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On January 13, Him Das, the acting head of the Financial Crimes Enforcement Network (FinCEN), highlighted ransomware as a chief national security risk. At the Financial Crimes Enforcement Conference, Das suggested that the...more

Morgan Lewis

FinCEN Releases Advance Notice of Proposed Rulemaking on New Beneficial Ownership Reporting Requirement

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The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on April 1 took the first step towards implementing the Corporate Transparency Act’s (CTA’s) beneficial ownership reporting requirements,...more

American Conference Institute (ACI)

[Virtual Event] Anti-Money Laundering and Financial Crime - May 4th - 5th, 9:45 am - 5:15 pm EST

The Canadian Institute’s 20th Canadian Annual Forum on AML and Financial Crime is a curated program, dedicated to addressing pressing industry challenges through in-depth analysis of the financial crime landscape and industry...more

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