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FinCEN › Banks › Due Diligence

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 -
Nutter McClennen & Fish LLP

Nutter Bank Report: February 2024

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The U.S. Department of Justice (DOJ) and state authorities have agreed to a consent order with a large national bank to resolve allegations that the bank engaged in a pattern or practice of lending discrimination by affecting...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

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

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In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

Moore & Van Allen PLLC

Will Congress Clarify Regulation of Marijuana-Related Business?

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President Trump piqued the interest of participants in and observers of the marijuana industry when he stated in early June that he would “probably” support recently proposed bipartisan legislation aimed at removing the...more

A&O Shearman

Wolfsberg Group Updates Correspondent Banking Due Diligence Questionnaire

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The Wolfsberg Group has published an updated version of its Correspondent Banking Due Diligence Questionnaire (dated February 22, 2018). The CBDDQ has been enhanced and expanded in line with regulatory expectations on...more

Dechert LLP

FinCEN Issues Advisory on Widespread Public Corruption in Venezuela

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The Financial Crimes Enforcement Network (FinCEN) released an advisory on September 20, 2017, to alert financial institutions of widespread public corruption in Venezuela and the methods Venezuelan senior political figures...more

Akin Gump Strauss Hauer & Feld LLP

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

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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

K2 Integrity

State Ballot Wins Only Amplify Questions About Pot Banking

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The 2016 election will be remembered not only for the memorable presidential race but also for what was effectively a national referendum on cannabis. Eight states passed laws allowing its use. Medical marijuana is now...more

Goodwin

FinCEN Issues Final Customer Due Diligence Rule

Goodwin on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has expanded the due diligence obligations of certain financial institutions that are subject to a customer identification program requirement under...more

Pillsbury Winthrop Shaw Pittman LLP

A New Age of Transparency: U.S. Announces

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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"

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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

WilmerHale

FinCEN Proposes AML Requirements for Registered Investment Advisers

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The Financial Crimes Enforcement Network (FinCEN) has proposed long-expected regulations that would extend anti-money laundering (AML) requirements to federally registered investment advisers (RIA). The August 25, 2015...more

McGuireWoods LLP

FinCEN Final Rule on Foreign Bank Requires Covered Financial Institutions to Take “Special Measures”

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On July 22, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published in the Federal Register a final rule pursuant to Section 311 of the Patriot Act against FBME Bank Ltd. (FBME,...more

Skadden, Arps, Slate, Meagher & Flom LLP

"FinCEN Proposes Tighter Customer Due Diligence Requirements for Financial Institutions"

Skadden, Arps, Slate, Meagher & Flom LLP on

For financial institutions, customer due diligence may become tougher and costlier in 2015 if the Financial Crimes Enforcement Network's (FinCEN) latest proposed rule is finalized in its current form. On July 30, 2014, FinCEN...more

Eversheds Sutherland (US) LLP

FinCEN Customer Due Diligence Rule Proposal

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On July 30, 2014, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules (the “Proposed Rules”) to clarify and strengthen customer due diligence requirements for banks, securities...more

Troutman Pepper

FinCEN Proposes Fifth BSA Pillar

Troutman Pepper on

On July 30, 2014, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (the Proposed Rule) to clarify and strengthen customer due diligence (CDD) requirements as a fifth pillar under the...more

Goodwin

FINCEN Issues Proposed Revisions to its Regulations That Would Enhance Financial Institutions’ Customer Due Diligence Requirements

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The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has proposed revisions (the “Proposal”) to its rules implementing the Bank Secrecy Act (the “BSA”) that would spell out specific anti-money...more

Morgan Lewis

FinCEN Proposes to Expand Financial Institution Customer Due Diligence Requirements

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The proposal would require financial institutions to identify beneficial owners of legal entities and codify existing customer due diligence guidance....more

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