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)
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more
Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more
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
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
On 12 June 2024, K2 Integrity and Schulte Roth & Zabel hosted a webinar discussing new regulatory obligations anticipated under proposed rules for investment advisers (IAs), timelines for finalization and compliance, and how...more
A press release was recently issued describing a significant joint proposal by the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The proposal...more
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
Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...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
The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more
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
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
The Financial Crimes Enforcement Network (“FinCEN”) has published a Small Entity Compliance Guide (the “Guide”) for beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act (“CTA”), as well as...more
The US Treasury’s Financial Crimes Enforcement Network (FinCEN) recently proposed a new rule (the Proposed Rule) regarding beneficial ownership information access and safeguards pursuant to the Corporate Transparency Act....more
The U.S. Department of the Treasury’s (the Treasury) Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated final rule on September 29, 2022, implementing the beneficial ownership information (BOI)...more
On December 8, 2021, the Financial Crimes Enforcement Network (FinCEN) published in the Federal Register its first installment of widely anticipated Proposed Rules regarding the Corporate Transparency Act of 2019 (CTA). The...more
On December 7, 2021, the Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued a highly anticipated notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting...more
The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week a Notice of Proposed Rulemaking (NPRM) to implement the beneficial ownership reporting requirements set forth in the Corporate...more