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Financial Crimes

White & Case LLP

FinCEN Issues Final Sweeping AML Requirements for Registered Investment Advisers & ERAs

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On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more

Troutman Pepper

FinCEN Publishes Updated FAQs Regarding CTA Filings for Dissolved Entities and Withdrawn Foreign Entities

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On September 10, the Financial Crimes Enforcement Network (FinCEN) published updated guidance in the form of new and revised frequently asked questions (FAQs), C.14-C.16 and G.4, regarding beneficial ownership information...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Skadden, Arps, Slate, Meagher & Flom LLP

New ‘Failure To Prevent Fraud’ Offence Expected To Come Into Force in the UK Shortly

The UK government introduced a major overhaul of its framework for addressing financial crime — and brought into force numerous significant changes — when the Economic Crime and Corporate Transparency Act 2023 (the Act)...more

Cole Schotz

Corporate Transparency Act – Filing Deadline Quickly Approaching for Entities Formed Prior to January 1, 2024

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Effective January 1, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) required certain newly formed and pre-existing entities to submit information regarding their beneficial owners and...more

A&O Shearman

Financial Conduct Authority Talks about a Targeted and Outcomes-Based Approach to Tackling Financial Crime

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The Financial Conduct Authority has published a speech by Sarah Pritchard, FCA Executive Director, Markets and International, on taking a targeted and outcomes-based approach to tackling financial crime....more

McDermott Will & Emery

US Attorney’s Office in California Announces Voluntary Self-Disclosure and Whistleblower Program for Corporate, Financial Crimes

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On August 23, 2024, the US Attorney’s Office for the Central District of California, which is the largest judicial district in the United States, announced a new Voluntary Self-Disclosure and Whistleblower Pilot Program. The...more

Stinson LLP

The Final Countdown: Major CTA Reporting Deadline Rapidly Approaching

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Barring any unforeseen changes, the Corporate Transparency Act's (CTA) major reporting deadline arrives on January 1, 2025. The CTA requires all existing reporting companies (those entities formed prior to January 1, 2024) to...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Conyers

Shifting Sands: The Future of Offshore Regulatory Disputes (Part 1)

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As an evolving area of commercial disputes in the Cayman Islands, global enforcement trends provide us with valuable insight into the types of regulatory proceedings on the horizon for offshore jurisdictions. In this first...more

Locke Lord LLP

Duty to File and Update U.S. Corporate Transparency Act Beneficial Ownership Reports

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As reported in our earlier QuickStudies on the Corporate Transparency Act (the “CTA”) and the Regulations adopted by the Financial Crimes Enforcement Network (“FinCEN”), each company in existence on or after January 1, 2024...more

Society of Corporate Compliance and Ethics...

Corruption and modern slavery

In my July column, I wrote about the connection between corruption and the environment. But corruption also has a link to the “S” of the environmental, social, and governance (ESG) pillars. Corruption is both a cause and a...more

McCarter & English Blog: Government Contracts...

A New Frontier in Corporate Accountability: The DOJ’s Corporate Whistleblower Awards Pilot Program

On August 1, 2024, the US Department of Justice (DOJ) Criminal Division introduced its Corporate Whistleblower Awards Pilot Program (Program), which, like a modern-day Western posse, aims to bring justice to the wild frontier...more

Parker Poe Adams & Bernstein LLP

The Corporate Transparency Act: Key Deadline Fast Approaching and Other Recent Updates for Companies

If your business has not yet focused on the Corporate Transparency Act (CTA), it is time to do so. Every entity formed or registered in the U.S. before January 1, 2024, must file beneficial ownership information (BOI) reports...more

Otten Johnson Robinson Neff + Ragonetti PC

Updated FinCEN Guidance on the Corporate Transparency Act

The Corporate Transparency Act (the CTA) went into effect on January 1, 2024 (the Effective Date) and imposed beneficial ownership information (BOI) reporting requirements on any entity that is created or registered by filing...more

Foodman CPAs & Advisors

FinCEN BOI 7/8/24 FAQs

El 7/8/24, FinCEN actualizó su página de preguntas frecuentes de BOI para incluir tres nuevas preguntas y una nueva actualización. FinCEN afirma que continuará brindando orientación sobre cómo presentar información sobre...more

Foodman CPAs & Advisors

FinCEN BOI FAQs 7/8/24

On 7/8/24, FinCEN updated its BOI FAQs page to include three new questions and one new update. FinCEN states that it will continue to provide guidance on how to submit beneficial ownership information; including updating the...more

Ballard Spahr LLP

Year-End CTA Filing Deadline Is Quickly Approaching

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The federal Corporate Transparency Act (CTA) became effective on January 1, 2024, and despite multiple challenges and ongoing court cases, the CTA remains in effect. The CTA requires many entities to file beneficial ownership...more

Polsinelli

New Government Reporting Requirements That May Apply To You

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If you or your trust owns an interest in a corporation, limited liability company, partnership, or other type of entity, subject to limited exceptions, you are likely required to provide certain information to the FinCEN...more

Jones Day

FinCEN Clarifies Application of Beneficial Ownership Reporting Rules to Dissolved Entities

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Reporting companies should take note of a recent clarification by the Financial Crimes Enforcement Network ("FinCEN") that the Beneficial Ownership Information ("BOI") Rule requires reporting companies that exist on or after...more

K2 Integrity

Pending FinCEN Investment Adviser Rule: Industry Perspective On Next Steps You Should Be Taking

K2 Integrity on

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

Ballard Spahr LLP

Nevada Gaming Control Board Alleges Casino AML Failures Based on Wagering of Customers Involved in Illegal Bookmaking

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The Nevada Gaming Control Board (“Board”) recently filed a complaint (“Complaint”) against Resorts World Las Vegas casino (“Resorts World”), alleging that, despite repeated red flags, Resorts World’s Anti-Money Laundering...more

Husch Blackwell LLP

Cannabis Law Now Podcast: Cannabis Companies and the Corporate Transparency Act

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The Corporate Transparency Act (CTA) seeks to increase corporate transparency and combat financial crimes in the U.S. such as money laundering and terrorist financing. Enacted in January 2021 as part of the National Defense...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Orrick, Herrington & Sutcliffe LLP

Illinois enacts the Uniform Money Transmission Modernization Act

On August 9, the Governor of Illinois signed SB 3412 (the “Act”) into law, creating a new regulatory framework for money transmission. This Act, named the Uniform Money Transmission Modernization Act, replaces the previous...more

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