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FinCEN › Comment Period

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 -
Vedder Price

SEC and FinCEN Propose Customer Identification Program Requirements for Investment Advisers

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On May 13, 2024, the SEC and FinCEN jointly proposed a new rule under the Bank Secrecy Act (BSA) that would impose new customer identification program (CIP) requirements on registered investment advisers and exempt reporting...more

Kramer Levin Naftalis & Frankel LLP

SEC and FinCEN Propose Rule Requiring Investment Advisers to Enact Customer Identification Programs

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On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department announced a joint notice of proposed rulemaking that would require investment...more

BCLP

SEC and FinCEN Propose Rules to Impose Customer Identification Program Obligations on Certain Investment Advisers

BCLP on

On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

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On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Stinson LLP

SEC, FinCEN Propose Customer Identification Program Requirements for RIAs and ERAs

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On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking (proposed rule) that would impact how investment advisers handle...more

McGlinchey Stafford

Rescheduling Marijuana FAQs: How Do I Submit Comments on DEA’s Proposed Rules?

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On May 16, 2024, the U.S. Drug Enforcement Administration (DEA) released the proposed rule (Proposed Rule) to reschedule marijuana from Schedule I to Schedule III under the Controlled Substances Act (CSA). The Office of Legal...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

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The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

Troutman Pepper

FinCEN Proposes Loosening Customer Identification Program Requirements

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On March 29, the Federal Crimes Enforcement Network (FinCEN), in collaboration with other federal agencies, issued a Notice and Request for Information and Comment (Notice and Request) seeking public comment on its proposal...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on

On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

Stark & Stark

Proposed AML Suspicious Activity Rule

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On February 13, 2024, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule to combat criminals and foreign adversaries from exploiting the U.S. financial system through investment...more

Troutman Pepper

FinCEN Proposes Extending AML/CFT Requirements to Certain Investment Advisors

Troutman Pepper on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently announced a Notice of Proposed Rulemaking (NPRM) aimed at keeping bad actors from exploiting the U.S. financial system and assets...more

Troutman Pepper

FinCEN's Proposed New Rule to Increase Reporting Requirements in Residential Real Estate

Troutman Pepper on

On February 7, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a new rule to increase reporting requirements for nonfinanced, entity-purchased residential real estate. FinCEN...more

K2 Integrity

[Webinar] Implications of FinCEN's Notice of Proposed Rulemaking on Virtual Currency Mixers - January 17th, 9:00 am PT

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Join K2 Integrity Global Co-managing Partner and Chief Strategy Officer Juan Zarate and Coinbase Global Head of Financial Crimes Compliance Valerie-Leila Jaber for a discussion of FinCEN’s notice of proposed rulemaking on...more

Davis Wright Tremaine LLP

Banking and Consumer Regulatory Digest - November 2023

Davis Wright Tremaine LLP on

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Orrick, Herrington & Sutcliffe LLP

FinCEN announces NPRM for new regulation to combat CVC mixing

Orrick, Herrington & Sutcliffe LLP on

On October 19, FinCEN announced a notice of proposed rulemaking (NPRM) that identifies international Convertible Virtual Currency mixing (CVC) as a primary money laundering concern. In its NPRM, FinCEN highlighted the...more

Ballard Spahr LLP

CTA Round-Up: FinCEN Proposes Extended CTA Filing Deadline, Revised Reporting Form, and Privacy Act Exemption; Expands CTA FAQs;...

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The Financial Crimes Enforcement Network (“FinCEN”) has issued a flurry of publications relating to the Corporate Transparency Act (“CTA”).  They pertain, in part, to a proposed extension of the filing deadline for certain...more

McGlinchey Stafford

FinCEN Invites Comment on Final Beneficial Ownership Information Reporting Rule

McGlinchey Stafford on

On January 17, 2023, the Financial Crimes Enforcement Network (FinCEN) published a notice inviting comment on the Beneficial Ownership Information Reporting Requirements final rule (Final BOI Reporting Rule) that was...more

Orrick, Herrington & Sutcliffe LLP

FinCEN solicits feedback on beneficial ownership reporting requirements

Orrick, Herrington & Sutcliffe LLP on

On January 17, the Financial Crimes Enforcement Network (FinCEN) published two notices and requests for comment in the Federal Register related to the reporting process the agency intends to use to collect beneficial...more

Ballard Spahr LLP

FinCEN Requests Comment on Proposed Beneficial Ownership Reporting Form

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Form Repeatedly Invites Response of “Unknown” As to Critical Information - The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice and request for comment (“Notice”) on the proposed form to collect and...more

Ballard Spahr LLP

FinCEN Seeks Public Comments on No-Action Letters

Ballard Spahr LLP on

On June 3, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an Advance Notice of Proposed Rulemaking (“ANPRM”) that seeks public comment on the implementation of a “no-action letter” process at FinCEN. The...more

McGuireWoods LLP

FinCEN Proposes No-Action Letter Process

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On June 3, 2022, the Financial Crimes Enforcement Network (FinCen) issued an Advance Notice of Proposed Rulemaking proposing public comment on the enactment of a no-action letter process. This Advanced Notice follows...more

Goodwin

Stress Test Scenarios Released for 2022

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In This Issue. The Federal Reserve Board of Governors (Federal Reserve), the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) released stress test scenarios to assess...more

Goodwin

SEC Proposes Changes to Private Fund Regulation

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

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