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Customer Due Diligence (CDD) Financial Institutions

Holland & Knight LLP

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more

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

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...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

Holland & Knight LLP

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more

Troutman Pepper

Federal Banking Agencies Reiterate Guidance on Managing Risks Posed By Fintech Partnerships and Other Third Party Relationships

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Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...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

King & Spalding

Request for Comments on FinCEN and SEC rule on CIP

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The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and 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

Recent FDIC consent orders show increased regulation scrutiny of bank relationships with fintech partners

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In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...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

Locke Lord LLP

FUNDamentals: FinCEN [Re]Proposes Anti-Money Laundering Rules for Investment Advisers

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On February 13, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule that would require federal investment advisers to add Bank Secrecy Act (“BSA”) type anti-money...more

Ballard Spahr LLP

Federal District Court Ruling: The CTA is Unconstitutional

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On March 1, Judge Liles C. Burke of the Northern District of Alabama issued a Memorandum Opinion (“Opinion”) and Final Judgment, finding that the Corporate Transparency Act (“CTA”) is unconstitutional....more

Troutman Pepper

FinCEN Proposes New Investment Adviser AML Rule

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On February 1/3, the Financial Crimes Enforcement Network (FinCEN) proposed a new rule (the Proposed Rule), that, if adopted, would add certain investment advisers to the definition of “financial institution” under the Bank...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

McGuireWoods LLP

FinCEN Issues Access Rule Compliance Guide for Beneficial Ownership Information

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Rule Regarding Access to Beneficial Ownership Information Takes Effect - On February 21, 2024, FinCEN published a Small Entity Compliance Guide to aid in compliance with the Corporate Transparency Act’s (“CTA”) Beneficial...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

Mayer Brown

Third Time’s the Charm? Anti-Money Laundering Compliance Requirements Proposed for Registered and Exempt Reporting Investment...

Mayer Brown on

On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more

Ballard Spahr LLP

Final CTA Access Rule Answers Some Questions, and Leaves Open Others

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The beneficial ownership information (“BOI”) registry under the Corporate Transparency Act (“CTA”) is now up and running at the Financial Crimes Enforcement Network (“FinCEN”). This post will follow up on a previous blog...more

Holland & Knight LLP

FinCEN Issues Final Rule Implementing Access and Safeguard Provisions of the CTA

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The Corporate Transparency Act (CTA) was enacted in 2021 and became effective on Jan. 1, 2024. The CTA was passed with the aim of enhancing transparency in corporate ownership, so as to combat the proliferation of anonymous...more

Dorsey & Whitney LLP

FinCEN’s Final Regulations to Implement the Corporate Transparency Act

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Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

Eversheds Sutherland (US) LLP

Key highlights of FinCEN’s final rule on access to Beneficial Ownership Information

The Financial Crimes Enforcement Network (FinCEN) issued the Beneficial Ownership Information Access and Safeguards Rule (Access Rule) establishing the framework for access to and protection of beneficial ownership...more

Goodwin

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

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On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

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