News & Analysis as of September 24, 2024

FinCEN › CARES Act

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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 -

FinCEN Update to Beneficial Ownership FAQs and Paycheck Protection Program FAQs

McGlinchey Stafford on 2/6/2024

In January 2024, the Financial Crimes Enforcement Network (FinCEN) updated and added to its Frequently Asked Questions (FAQs) on the Beneficial Ownership Information Report (BOI) website. Additionally, on January 12, 2024,...more

FinCEN Issues Alert on COVID-19 Employee Retention Tax Credit Fraud

Ballard Spahr LLP on 11/29/2023

On November 22, 2023, the Financial Crimes Enforcement Network (“FinCEN”), in close coordination with the Internal Revenue Service (“IRS”) Criminal Investigation (“CI”), issued an alert (“Alert”) regarding the COVID-19...more

Federal Authorities Focusing on PPP Fraud

Steptoe & Johnson PLLC on 5/13/2021

With the light at the end of the tunnel getting brighter on our pandemic journey, the legal realities are only just beginning. The Department of Justice has prioritized the prosecution of fraud arising from the Paycheck...more

Closer Scrutiny Expected of Corporate Conduct

Skadden, Arps, Slate, Meagher & Flom LLP on 4/30/2021

The Biden administration is widely expected to be tougher on corporate wrongdoing than its predecessor. Although there have not yet been significant changes to existing policies, key nominations to date and early enforcement...more

FinCEN Advisory and Notice on Financial Crimes Targeting COVID-19 Economic Impact Payments

Foley & Lardner LLP on 3/16/2021

On February 24, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an advisory alerting financial institutions to the potential for fraud and other financial crimes related to Economic Impact Payments (EIPs) and a...more

FinCEN Warns Financial Institutions About Economic Stimulus Aid Scams

Ballard Spahr LLP on 3/1/2021

The Financial Crimes Enforcement Network (“FinCEN”) issued on February 24, 2021 “an [A]dvisory to alert financial institutions to fraud and other financial crimes related to Economic Impact Payments (EIPs), authorized by the...more

New PPP Procedural Requirements Reflect Lenders’ Emerging AML Duties

Ballard Spahr LLP on 2/26/2021

The Small Business Administration (“SBA”) recently issued a procedural notice (the “Notice”) to “All SBA Employees and Paycheck Protection Program Lenders” setting forth “Revised SBA Paycheck Protection Platform Procedures...more

Nutter Bank Report: February 2021

Nutter McClennen & Fish LLP on 2/25/2021

HUD, VA, and USDA Coordinate Extensions of COVID-19 Relief for Homeowners - The U.S. Department of Housing and Urban Development (HUD), the U.S. Department of Veterans Affairs (VA), and the U.S. Department of Agriculture...more

FinCEN Issues PPP Lender Guidance

Ballard Spahr LLP on 2/12/2021

With the third round of lending through the Paycheck Protection Program (“PPP”) in full swing, the Small Business Administration (“SBA”) – administrator of the PPP – has developed new guidance in consultation with the United...more

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - October 2020 #3

Troutman Pepper on 10/27/2020

Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). In response, Troutman Pepper developed a dedicated COVID-19 Resource Center to guide...more

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

Ballard Spahr LLP on 9/3/2020

Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

SBA Inspector General Management Alert And FinCEN Advisory Highlight Banks’ Role In Combating COVID-19 Loan Fraud

Vinson & Elkins LLP on 8/7/2020

On July 28, 2020, the Small Business Administration’s (“SBA”) Inspector General (“IG”), Hannibal “Mike” Ware, issued a Management Alert informing SBA Administrator Jovita Carranza that the IG’s preliminary review of the...more

Nutter Bank Report: July 2020

Nutter McClennen & Fish LLP on 7/30/2020

SBA Issues Instructions to Lenders on Submitting PPP Loan Forgiveness Applications The U.S. Small Business Administration (the “SBA”) has issued a procedural notice announcing that the SBA will begin accepting forgiveness...more

Financial Services Report, Summer 2020

Morrison & Foerster LLP on 7/15/2020

Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more

Financial Institutions Can No Longer Afford to Underfund Compliance Hiring and Training

Foodman CPAs & Advisors on 6/18/2020

The Covid-19 Pandemic and the accompanying reduction in economic activity has been a rationale for Financial Institutions (FI) to re-analyze their budgets for compliance training and education. FIs, as well as businesses in...more

The Main Street Business Lending Program – Updated Frequently Asked Questions

White and Williams LLP on 6/3/2020

On May 27, 2020, the Federal Reserve Bank of Boston (FRBB) released a significantly updated set of “Frequently Asked Questions” (Updated FAQs), offering additional insight into the details of the Main Street Business Lending...more

FATF Issues Paper on COVID-19 Enhanced AML and Fraud Risks

Ballard Spahr LLP on 5/11/2020

On May 4, the Financial Action Task Force (“FATF”) issued a paper entitled “Covid-19-Related Money Laundering and Terrorist Financing – Risk and Policy Responses (“Paper”). ...more

FinCEN re-clarifies FAQ’s on how Lenders can meet BSA requirements when issuing PPP loans

Foodman CPAs & Advisors on 5/1/2020

On April 13, 2020, FinCEN, as the administrator of the BSA, re-published FAQs on how borrowers and lenders may rely on the guidance provided for the SBA’s interpretation of the CARES Act and of the PPP (Paycheck Protection...more

Bank Secrecy Act Compliance Issues for Small-Business Lending Under the CARES Act

Manatt, Phelps & Phillips, LLP on 4/21/2020

With many banks and credit unions electing to limit Paycheck Protection Program (PPP) loans to existing customers, many nonbank lenders are scrambling to fill the gap and take part in the $349 billion program prior to the end...more

AI Meets the Paycheck Protection Program: FinCEN FAQs Underscore How the Regulatory Response to the Pandemic Is Accelerating the...

Davis Wright Tremaine LLP on 4/20/2020

The COVID-19 pandemic provides a stark reminder about the importance of responding to rapid changes in a timely and expeditious manner. In the span of a few weeks, unemployment levels have skyrocketed to unprecedented levels,...more

FinCEN Issues COVID-19 AML Update for Financial Institutions

Ballard Spahr LLP on 4/10/2020

Some Commentary on the Unfortunate Relationship Between Crisis and Fraud - The Financial Crimes Enforcement Network (“FinCEN”) released an update (“Update”) on its March 16, 2020 COVID-19 Notice, on which we previously...more

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FinCEN › CARES Act

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