News & Analysis as of

FinCEN Banking Sector Customer Due Diligence (CDD)

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on

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

Goodwin

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

Goodwin on

On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

Davis Wright Tremaine LLP

FinCEN Beneficial Ownership Information Access Proposal Raises Many Questions

As described in DWT's October 2021 post, the Corporate Transparency Act ("CTA"), enacted as part of the Anti-Money Laundering Act of 2020, establishes beneficial ownership reporting requirements for a broad range of entities...more

Ballard Spahr LLP

FinCEN and Federal Functional Regulators Issue Coded Warnings Against De-Risking

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OOn July 6, the Financial Crimes Enforcement Network (“FinCEN”), The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the...more

Nutter McClennen & Fish LLP

The Corporate Transparency Act: FinCEN to Collect Beneficial Ownership Information

The Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA is to deter anonymous owners of corporations, limited liability companies, and other entities from...more

Ballard Spahr LLP

U.S. Passes Historic BSA/AML Legislative Change

Ballard Spahr LLP on

First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime - Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2020

FDIC Modernizes Brokered Deposit Rule and Amends Interest Rate Restrictions - The FDIC has adopted a final rule that establishes new standards for determining whether deposits made through certain kinds of arrangements...more

Nutter McClennen & Fish LLP

Nutter Bank Report: November 2020

Federal Banking Agencies Issue New Guidance on Managing the LIBOR Transition - The member agencies of the Federal Financial Institutions Examination Council (“FFIEC”) have issued joint guidance for banking organizations...more

Faegre Drinker Biddle & Reath LLP

Regulators Issue Guidance on U.S. Banks’ Reporting Obligations Regarding Suspected Foreign Corrupt Practices

In response to inquiries from the financial industry as to how to assess risks of potential illegal activity with respect to beneficial owners who are “politically exposed persons” (PEPs) overseas, federal bank regulators...more

NAVEX

Clarifying New Customer Due Diligence (CDD) Guidance on PEPs

NAVEX on

Compliance officers in financial services have long struggled with aspects of Customer Due Diligence, better known as the CDD Rule. This fall, compliance professionals are scratching their heads to know exactly how much due...more

Ballard Spahr LLP

Joint Statement Clarifies Due Diligence Expectations for Politically Exposed Persons

Ballard Spahr LLP on

Regulators’ Joint Statement Attempts to Clarify AML Expectations Regarding Potential Corrupt Actors - On August 21, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and other banking regulators –...more

BCLP

FinCEN Clarifies Customer Due Diligence Requirements

BCLP on

The Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department recently issued clarifications of requirements for Customer Due Diligence (CDD) under the Customer Due Diligence Requirements for Financial...more

Sheppard Mullin Richter & Hampton LLP

Clearing the Air: FinCEN Guidance May Help Banks Find Their Way in the Field of Hemp Financing

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

Ballard Spahr LLP

The Banking of Cannabis and Hemp-Related Customers: An Update

Ballard Spahr LLP on

We are really pleased to presenting on July 9, 2020 to the National Association of Federally-Insured Credit Unions (“NAFCU”) on banking issues relating to cannabis. The cannabis and hemp industry continues to pose a...more

BCLP

FinCEN Extends Temporary Beneficial Ownership Rule Relief for Older Autorenewing Products

BCLP on

The temporary exception that FinCEN extended to autorenewing CDs and loans established prior to the May 11, 2018 compliance effective date of its beneficial ownership requirements was scheduled to expire on August 9, 2018. ...more

A&O Shearman

FinCEN Provides Temporary Exception Under the Beneficial Ownership Rule for CDs and Loan Accounts that Automatically Rollover or...

A&O Shearman on

The U.S. Financial Crimes Enforcement Network announced that it was granting a 90-day exception from compliance with the beneficial ownership requirements under its Customer Due Diligence Requirements for Financial...more

A&O Shearman

FFIEC Publishes Customer Due Diligence and Beneficial Ownership Overviews and Examination Procedures

A&O Shearman on

The U.S. Board of Governors of the Federal Reserve System, U.S. Office of the Comptroller of the Currency, and U.S. Federal Deposit Insurance Corporation published the customer due diligence and beneficial ownership...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Customer Due Diligence Requirements Will Affect Certain Securities Offerings

Beginning May 11, 2018, the new Financial Crimes Enforcement Network (FinCEN) customer due diligence rule (the “CDD Rule”) will require covered financial institutions to identify, and verify the identity of, the beneficial...more

A&O Shearman

FinCEN’s Customer Due Diligence Rule Becomes Effective; FinCEN and FINRA Guidance Provides Interpretive Color for Firms Working to...

A&O Shearman on

May 11, 2018 marked the compliance date for the Customer Due Diligence Requirements for Financial Institutions rule issued by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) on May 11, 2016 (the...more

Sullivan & Worcester

Customer Due Diligence and FinCEN’s Frequently Asked Questions

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As you are aware, FinCEN’s Customer Due Diligence rules are effective in two days. In a nutshell, these rules require banks to obtain and verify the identity of the beneficial owners of new business customers. The rules are...more

Nelson Mullins Riley & Scarborough LLP

Top Ten Key Points from FinCEN’s Recent Guidance Regarding the CDD Rule

Mere weeks before the mandatory compliance deadline of May 11, 2018, FinCEN answered 37 of the most frequently asked questions by covered financial institutions regarding the implementation of its Customer Due Diligence...more

Foodman CPAs & Advisors

Here is what you need to know about the FinCEN’s Final CDD Rule effective May 11, 2018

Covered Financial Institutions (CFI) have until May 11, 2018 to implement and comply with the Financial Crimes Enforcement Network (FinCEN) Final Customer Due Diligence Rule (the CDD Rule). The CDD Rule imposes a new...more

Nutter McClennen & Fish LLP

Nutter Bank Report, April 2018

Treasury Report Recommends Changes to Community Reinvestment Act Rules - The U.S. Department of the Treasury has released a report recommending changes to the federal banking agencies’ rules that implement the Community...more

The Volkov Law Group

FinCEN Issues Guidance for Beneficial Ownership Regulations

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Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly...more

K2 Integrity

Is Your AML Program Up to the Task?

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Fulfilling today’s requirements for anti-money laundering and counterterrorism financing/sanctions compliance is no easy task for financial institutions. ...more

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