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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

A Roadmap to the CTA’s Game-Changing Reporting Requirements

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Beginning on January 1, 2024, many U.S. legal entities and foreign entities registered to do business in the U.S. will be required to report information about themselves, their beneficial owners, and their company applicants...more

Dorsey & Whitney LLP

FinCEN Proposes Regulations to Implement the BSA’s Revised Legal Entity Requirements

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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 December 8, 2021, the Financial Crimes Enforcement...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

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Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Blank Rome LLP

New Treasury Regulations Impose Conflicting Requirements on Foreign Persons with U.S. Interests

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Few Americans consider the United States to be a money laundering haven, but it is. Earlier this year, the European Parliament wrote: - The USA is seen as an emerging leading tax and secrecy haven for rich foreigners, when...more

Ballard Spahr LLP

FINCEN Advises That Participation in a Foreign Tax Regularization Program By Itself Does Not Trigger SAR Filing Obligation

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The Financial Crimes Enforcement Network (“FinCEN”) recently advised that a financial institution is not required to file a Suspicious Activity Report (“SAR”) based solely upon a customer’s inquiry into or participation in a...more

Vedder Price

Annual Compliance Obligation Reminders

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Investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or with a state (“Advisers”) as well as commodity pool operators (“CPOs”) and commodity trading advisors (“CTAs”) registered with the...more

Foodman CPAs & Advisors

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

Baker Donelson on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

K&L Gates LLP

AML Update: The Rumors Are True – FinCEN Proposes Regulations That Will Require SEC Registered Investment Advisers to Adopt an AML...

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On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more

Goodwin

Financial Services Weekly News - September 2015 #2

Goodwin on

Regulatory Developments: DOL Releases Transcripts of Fiduciary Standard Hearings - The Department of Labor (DOL) has released the transcripts of the hearings held by the agency in August on its proposed fiduciary...more

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