How Will the Anti-Money Laundering Act of 2020 and the Corporate Transparency Act Impact Banks’ Anti-Money Laundering Compliance Under the Bank Secrecy Act? A Discussion with Guest Matt Haslinger
Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)
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
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
On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more
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
Without much fanfare, the Financial Crimes Enforcement Network (FinCEN) published in June its Spring 2023 Rulemaking Agenda, which provides proposed timelines for upcoming key rulemakings projected throughout the rest of...more
On March 16, 2003, the UK Financial Conduct Authority (FCA) published its letter Portfolio Letter: FCA priorities for payments firms to the CEOs of UK Payment Institutions (PIs), Electronic Money Institutions (EMIs), and...more
Knowing who owns legal entities is essential to stopping terrorism, money laundering, and other sophisticated criminal enterprises. For entities formed in the United States there has never been a requirement to disclose...more
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
Introduction - The art market is characterised by high-value, portable items that can be bought and exchanged quickly and often confidentially. These features, which make the market inherently vulnerable to many types of...more
Congress recently passed the Corporate Transparency Act (CTA) requiring private companies to disclose their beneficial owners to the United States Department of the Treasury’s Financial Crime Enforcement Network (FinCEN). The...more
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
Brexit - FCA provides information on the Temporary Permissions Regime (TPR) On 3 March, the FCA published new webpages providing information on the TPR. Firstly, the FCA published a webpage on how it will supervise firms...more
Anti-money laundering (“AML”) issues have been a focus of regulators and law enforcement for the past decade and will likely continue to be a priority issue area for the Biden Administration. The AML landscape is shifting...more
On New Year’s Day 2021, Congress passed—over President Trump’s veto—a defense appropriations law containing the Anti-Money Laundering Act of 2020 (“AML Act”) and the Corporate Transparency Act, as part of a sweeping new set...more
On May 1, 2020, the Federal Bureau of Investigation issued an intelligence bulletin warning, reported on in late July by several members of the media, concerning the use by threat actors of the “private placement of funds,...more
The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more
The Financial Action Task Force (FATF) recently published a report titled Virtual Assets: Red Flag Indicators of Money Laundering and Terrorist Financing. The report discusses a number of red flag indicators of suspicious...more
On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) published updated guidance intended to “enhance the availability of financial services” for the hemp industry (the Guidance). Even though the Agriculture...more
On May, 2020, the FATF published new money laundering and terrorist financing threats and vulnerabilities arising from the COVID-19 crisis. The document highlights how fraud, cybercrime, misdirection of government funding...more
Six steps can take institutions beyond merely good. What makes for a great anti-money laundering compliance program? This is not a pie-in-the-sky idea. As financial institutions strive to keep up with evolving regulations...more
On March 31st the Financial Action Task Force (FATF)—the global AML/CFT standard-setting body and watchdog—announced that it has upgraded the United States for technical compliance with FATF Recommendation 10 following...more
A new law, which came into force on 10 January, has ushered in material changes to the regulation of the art market, extending the application of the UK’s anti-money laundering legislation to the sector. The new law,...more
The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 have been published, amending the existing Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The...more
AMA Details Components of a Strong AML/BSA Program - Earlier this month, the American Gaming Association (“AGA”) released an updated Best Practices for Anti-Money Laundering (“AML”) Compliance (“Best Practices Guidance”)...more
Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more