News & Analysis as of

FinCEN › Beneficial Owner › Banks

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 -
Seyfarth Shaw LLP

The Corporate Transparency Act: Considerations for Special Purpose Entities in Commercial Real Estate Transactions

Seyfarth Shaw LLP on

Corporate structures in commercial real estate transactions can often be very complex and involve layers of entities. Special purpose entities that are bankruptcy remote (“SPEs”) are frequently used in commercial real estate...more

Woods Rogers

Corporate Transparency Act Reporting: What Banks Need to Know

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Most privately held domestic and foreign companies doing business in the United States must now report beneficial ownership information (BOI) to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN)...more

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

American Conference Institute (ACI)

[Event] 8th Forum on FinTech & Emerging Payment Systems - April 9th - 10th, New York, NY

American Conference Institute (ACI) on

ACI’s 8th Annual Legal, Regulatory, and Compliance Forum on Fintech & Emerging Payment Systems will provide in-depth guidance on the latest regulatory developments at the Federal and State Level that you need to be aware of....more

Mintz - Securities & Capital Markets...

New for 2024: Compliance with the Corporate Transparency Act Necessary for Many Mintz Clients

Mintz - Securities & Capital Markets... on

Reporting requirements under the Corporate Transparency Act (CTA) are in effect beginning January 1, 2024. Under the CTA, many US entities will be required to provide the personal information of their beneficial owners to the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

Nutter McClennen & Fish LLP on

A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Ballard Spahr LLP

Bank Industry Groups Heavily Criticize FinCEN’s Proposed Rule on Access to Beneficial Ownership Information

Ballard Spahr LLP on

On February 14, 2023, both the American Bankers Association (ABA) and the Bank Policy Institute (BPI) submitted comments to the Financial Crimes Enforcement Network (FinCEN) on FinCEN’s notice of proposed rulemaking (NPRM)...more

Nelson Mullins Riley & Scarborough LLP

An Assessment of FinCEN’s Uniform Beneficial Ownership Information Reporting Rules

Nelson Mullins Riley & Scarborough LLP on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued final rules on Sept. 30, 2022, implementing Section 6403 of the Corporate Transparency Act, also called the BOI Rules....more

Harris Beach PLLC

Beneficial Ownership Information Final Rule Affects Banks and Credit Unions

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On September 29, 2022, the Financial Crimes Enforcement Network (FinCEN) issued the first of three final rules implementing the Corporate Transparency Act’s beneficial ownership information (BOI) requirements. The aim of the...more

Moore & Van Allen PLLC

Client Alert: Beneficial Ownership Reporting at the Federal Level effective January 1, 2024

Moore & Van Allen PLLC on

Most entities formed or registered to do business in the U.S. will, beginning January 1, 2024, be required to self-report beneficial ownership information to the U.S. Treasury’s Financial Crimes Enforcement Network...more

Goodwin

OCC Seeks Feedback on Principles for Climate-Related Financial Risk Management

Goodwin on

In this Issue. The Office of the Comptroller of the Currency (OCC) is seeking feedback on principles for climate-related financial risk management for large banks; the Department of Justice’s Antitrust Division is seeking...more

Foodman CPAs & Advisors

FinCEN Is Seeking Feedback On The Corporate Transparency Act (CTA)

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The CTA is a recent reporting requirement that is expected to enhance U.S. national security through increasing the difficulty involved for harmful actors to exploit opaque legal structures for laundering money, financing...more

Williams Mullen

Congress Imposes Sweeping Beneficial Ownership Disclosure Requirements in the Corporate Transparency Act

Williams Mullen on

With the stated goal of “counter[ing] money laundering, the financing of terrorism, and other illicit activity,” the Corporate Transparency Act (the “Act”), adopted on January 1, 2021, imposes novel beneficial ownership...more

Morgan Lewis - All Things FinReg

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

Morgan Lewis - All Things FinReg on

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

Nutter McClennen & Fish LLP

Bank Report: October 2019

Nutter McClennen & Fish LLP on

Federal Banking Agencies Adopt Simplified Capital Calculation for Community Banks The federal banking agencies have issued a final rule that will simplify capital requirements for community banks by allowing them to adopt...more

Hudson Cook, LLP

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

Hudson Cook, LLP on

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

Pillsbury - Global Trade & Sanctions Law

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

Pillsbury - Global Trade & Sanctions Law on

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

Skadden, Arps, Slate, Meagher & Flom LLP on

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

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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

WilmerHale

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

WilmerHale on

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

K2 Integrity

FinCEN’s Beneficial Ownership Rule and Increased AML Burden

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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

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

Morgan Lewis on

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

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

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