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FinCEN › Financial Institutions › Compliance

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 -
Goodwin

FinCEN Adopts Final AML Program Rule for Investment Advisers

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

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Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more

Alston & Bird

Investment Advisers Face New AML/CFT Compliance Obligations from FinCEN

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Our Financial Services, Investment Funds, and White Collar, Government & Internal Investigations Teams break down the latest Financial Crimes Enforcement Network (FinCEN) rule investment advisers must prepare for....more

Holland & Knight LLP

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more

DLA Piper

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

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Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more

Mitratech Holdings, Inc

DOJ Unveils Whistleblower Rewards Program: What Every Business Needs to Know

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The Department of Justice has launched the Corporate Whistleblower Awards Pilot Program to fight corporate crime. See how it impacts your organization. The U.S. The Department of Justice (DOJ) has just rolled out the...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

The Volkov Law Group

FinCEN Issues Proposed Rule to Strengthen and Modernize Financial Institutions’ AML/CFT Programs

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On June 28, 2024, the Financial Crimes Enforcement Network released a notice of proposed rulemaking. The purpose of the proposed rule is to strengthen and modernize Anti-Money Laundering and Countering the Financing of...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

Holland & Knight LLP

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more

WilmerHale

FinCEN’s Proposed AML/CFT Program Rule Potentially Heralds a Change in Approach

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On June 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network announced long-anticipated proposed rules on anti-money laundering and countering the financing of terrorism program effectiveness;...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

Mayer Brown

FinCEN Proposes Rule Reinforcing Financial Institutions’ Duty to Design and Maintain Risk-Based AML/CFT Programs

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On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more

Holland & Knight LLP

FinCEN Issues Proposed Rule Amending Requirements of Financial Institutions' AML/CFT Programs

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on June 28, 2024, announced a proposed rule to "strengthen and modernize financial institutions' anti-money laundering and countering the...more

K&L Gates LLP

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

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Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

Mayer Brown Free Writings + Perspectives

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

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I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for May 2024

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SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

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There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

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Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

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On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

Wilson Sonsini Goodrich & Rosati

FinCEN Proposes Significant Expansion of AML/CFT Obligations to Cover Registered Investment Advisers, Venture Capital Advisers,...

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a sweeping expansion of the Bank Secrecy Act’s (BSA) affirmative anti-money laundering (AML) and countering the financing of...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

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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

Barnea Jaffa Lande & Co.

Risk to Israeli Entities Posed by International Sanctions – What Is the Exposure and What Are the Dangers?

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The executive order signed by United States President Joseph Biden in February 2024 states that the violence being committed by Israeli settlers has reached intolerable levels; poses a serious threat to peace, security, and...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

Alston & Bird

Structured Finance Spectrum – Winter 2024

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Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the shifting single-family rental landscape, what’s next for EDGAR, and...more

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