News & Analysis as of

FinCEN Banks 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 -
K2 Integrity

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

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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

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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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

Foodman CPAs & Advisors

CDD Friendly Reminder From The Agencies To The Banks

On 7/6/22, the Agencies (Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the...more

McGuireWoods LLP

Bank Regulators Remind Financial Institutions Not to Take a One-Size Fits All Approach to Assessing AML Risks from Customer...

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The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network, the National Credit Union Administration, and the Office of the Comptroller of the...more

McGuireWoods LLP

FinCEN Issues Statement on BSA Due Diligence for Independent ATM Owners and Operators

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On June 22, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a Statement on Bank Secrecy Act Due Diligence for independent ATM owners and operators. The purpose of the statement is to “provide clarity to banks...more

Morgan Lewis - All Things FinReg

FinCEN Expands AML, Customer Identification Programs, and Beneficial Ownership Requirements to Banks Lacking a Federal Functional...

The Financial Crimes Enforcement Network (FinCEN) issued a final rule that requires minimum standards for anti-money laundering (AML) programs for banks lacking a federal functional regulator (the Federal Reserve Board, OCC,...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

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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

Hudson Cook, LLP

Current Developments in Bank Deposits and Payment Systems (Spring 2019)

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This survey summarizes several recent developments affecting bank deposits and payment systems. The U.S. department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued new guidance concerning the customer...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

White & Case LLP on

TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Pillsbury - Global Trade & Sanctions Law

With CDD and Beneficial Ownership Rule in Effect, FinCEN Continues to Clarify and Refine Rules for Financial Institutions

Long awaited rules for “Customer Due Diligence Requirements for Financial Institutions” (the CDD Rules) went into effect on May 11, 2018. FinCEN has taken steps to clarify and refine implementation of the CDD Rules, issuing...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tackling the Challenges of Complying With FinCEN’s New Customer Due Diligence Rule

Effective May 11, 2018, covered financial institutions are required to comply with the customer due diligence rule (the Rule) that the Financial Crimes Enforcement Network (FinCEN) finalized in May 2016. The Rule mandates the...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

A&O Shearman

Financial Regulatory Developments Focus - April 2018 #2

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In this week's newsletter, we provide a snapshot of the principal U.S., European and global financial regulatory developments of interest to banks, investment firms, broker-dealers, market infrastructure providers, asset...more

WilmerHale

FinCEN Releases Frequently Asked Questions Regarding Customer Due Diligence and Beneficial Ownership Requirements

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Last week the Financial Crimes Enforcement Network (FinCEN) issued much-anticipated Frequently Asked Questions (FAQs) that provide additional guidance to financial institutions relating to the implementation of the new...more

BakerHostetler

Banks, Broker-Dealers and Other Financial Institutions Face May 11 Deadline To Comply with FinCEN’s Customer Due Diligence Rule

BakerHostetler on

Six years after the Financial Crimes Enforcement Network (FinCEN) originally proposed its Customer Due Diligence (CDD) Rule, the deadline for financial institutions to comply draws near. Banks, broker-dealers, mutual funds...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

Ballard Spahr LLP

2016 Year in Review: Money Laundering (Part One)

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2016 was a busy year for developments in Anti-Money Laundering (AML), the Bank Secrecy Act (BSA), the criminal money laundering statutes, forfeiture, and related issues. In part one of our year-in-review, we discuss six key...more

K2 Integrity

FinCEN’s Beneficial Ownership Rule and Increased AML Burden

K2 Integrity on

Compliance officers at financial institutions have made great strides in improving Know Your Customer (KYC) programs to focus on knowing their customers as a critical function in combating money laundering. As regulators...more

Cozen O'Connor

New FinCEN Proposal Will Extend AML Rules to Currently Exempt Banks and Other Institutions

Cozen O'Connor on

Seeking to close a perceived “gap” in regulations intended to facilitate the government’s efforts to curb money laundering and the financing of terrorism, the U.S. Department of the Treasury’s Financial Crimes Enforcement...more

Foodman CPAs & Advisors

Why is On-boarding and Off-boarding Bank Clients Important?

After the Panama Papers, and with the recent FinCEN final Customer Due Diligence (CDD) rule, U.S. financial institutions are further focused on tightening internal controls against money laundering, terrorist financing,...more

K&L Gates LLP

FinCEN Adopts New Customer Due Diligence Requirements for Financial Institutions

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The Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has adopted new anti-money laundering (“AML”) regulations that impose additional customer due diligence requirements on certain financial institutions...more

Morgan Lewis

FinCEN Requires Financial Institutions to Obtain Beneficial Ownership

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FinCEN’s new CIP beneficial owner rules may hinder the ability of shell and nominee companies to directly access the US financial system without disclosing the natural persons who own 25% or more of the company. Pooled...more

Pillsbury Winthrop Shaw Pittman LLP

A New Age of Transparency: U.S. Announces

On May 11, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury, published its final rule addressing Customer Due Diligence Requirements for Financial Institutions (CDD Rule)....more

Skadden, Arps, Slate, Meagher & Flom LLP

"FinCEN Finalizes Customer Due Diligence Rule Amid Other Actions to Enhance Financial Transparency"

In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more

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