Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)
Axiom Law: BigLaw's Friend or Enemy?
With so much focus on the regulatory treatment (and mistreatment) of blockchain related businesses, the benefits of commercial legal certainty for choosing a country or territory as a home of choice for these businesses is...more
As of Jan. 1, 2024, wide-reaching new regulations require many businesses and corporate entities created or registered to do business in the United States to report information regarding their owners, officers and other...more
Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more
Beginning on January 1, 2024, many U.S. legal entities and foreign entities registered to do business in the U.S. will be required to report information about themselves, their beneficial owners, and their company applicants...more
Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on December 8, 2021, the Financial Crimes Enforcement...more
The Financial Crimes Enforcement Network (“FINCEN”) announced on November 15 that it has renewed and revised its Geographic Targeting Orders (“GTOs”) that require U.S. title insurance companies to identify the natural persons...more
1. Fascicolo del Titolare Effettivo - Il Decreto Legislativo 25 maggio 2017, n. 90 (di seguito il "Decreto"), in vigore dal 4 luglio 2017, ha recepito la Direttiva 2015/849/UE e, ai fini del contrasto al riciclaggio e al...more
Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), currently in committee in the Senate. The CTIFA proposes the most substantial overhaul to the Bank Secrecy Act (“BSA”) since...more
On 25 June 2017, the new German Money Laundering Act came into force, which primarily implements the 4th European Anti-Money-Laundering Directive (EU 2015/849) into German law. Among others, the Act establishes a new...more
If you’ve been involved in the funds industry, you will be well aware of the ever-increasing focus on anti-money laundering and “know your customer” requirements by national and supranational regulatory bodies alike. In...more
Highlights - - Implementation of a public Transparency Register on beneficial ownership of legal entities. - Notification obligation applies to incorporated companies and certain other legal entities and arrangements;...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more
All Russian legal entities must obtain information on their ultimate beneficial owners. Russia has recently amended its anti-money laundering law to require that any legal entity, whether private or public (with limited...more
On May 11, 2016, FinCEN published in the Federal Register its long-awaited anti-money laundering (“AML”) rules (the “Final Rules”) governing corporate entities doing business with banks and other financial institutions that...more
The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more
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
On May 5, 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued final rules (the Final Rules) on customer due diligence requirements for banks, securities broker-dealers, mutual funds, and...more