News & Analysis as of

Customer Identification Program (CIP) Money Laundering

ArentFox Schiff

SEC and FinCEN Propose New Rule: Mandatory Customer Verification for Investment Advisers in 2024

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On May 13, the US Securities and Exchange Commission (SEC) and the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) jointly released a notice of proposed rulemaking (NPRM) which, if...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Ballard Spahr LLP

Recent FDIC Consent Orders Reflect Ongoing Scrutiny of Bank Relationships with Fintechs

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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 concerns relating...more

Ballard Spahr LLP

SEC Issues Alert Outlining Deficiencies in Broker-Dealers’ AML Compliance

Ballard Spahr LLP on

On July 31, 2023, the United States Securities and Exchange Commission (“SEC”) published an alert outlining deficiencies the Department of Examinations has observed in broker-dealers’ (“BD”) compliance with anti-money...more

McGlinchey Stafford

BSA, OFAC, KYC, and CIP – What do they mean to me? [More with McGlinchey, Ep. 29]

McGlinchey Stafford on

The Bank Secrecy Act (BSA) and parts of the U.S. Patriot Act’s Office of Foreign Asset Control (OFAC) requirements have seemingly similar goals: to prevent money laundering and the funding of terrorist activities. Yet a...more

Ballard Spahr LLP

SDNY Unveils First Criminal Prosecution of Broker-Dealer for Violating BSA

Ballard Spahr LLP on

For the first time, a broker-dealer, Central States Capital Markets, LLC (Central States), has been prosecuted for violating the Bank Secrecy Act (BSA). ...more

Ballard Spahr LLP

Banking Regulators Issue Exemption from CIP Requirements for Premium Finance Loans

Ballard Spahr LLP on

The Federal Banking Agencies (“FBAs”) — collectively the Office of the Comptroller of the Currency (“OCC”); the Board of Governors of the Federal Reserve System (“Federal Reserve”); the Federal Deposit Insurance Corporation...more

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