News & Analysis as of

National Security BSA/AML FinCEN

DLA Piper

SEC Actions Signal Warning to Investment Advisers Over-Promising on AML

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Earlier this month, the US Securities and Exchange Commission (SEC) charged a registered investment adviser (RIA) with willfully violating Section 206(4) of the Investment Advisers Act of 1940 by making misrepresentations...more

Foodman CPAs & Advisors

FinCEN Final New Rules Close Loopholes in U.S. Financial System

On August 28, 2024, FinCEN Final New Rules were published that address vulnerabilities in the U.S. financial system and are part of an on going effort to combat illicit finance and protect U.S. national security, as well as...more

White & Case LLP

FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs

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On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more

Goodwin

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

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On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

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On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

The Volkov Law Group

FINRA Reminds Broker-Dealers on Importance of Compliance with New AML Rules

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The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements.  There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will...more

Bilzin Sumberg

FinCEN Seeks Public Comment on Corporate Transparency Act

Bilzin Sumberg on

On April 1, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (the "Notice") seeking public comment on a myriad of issues related to the implementation of a beneficial...more

Foodman CPAs & Advisors

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

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

Lippes Mathias LLP

The Corporate Transparency Act: New Beneficial Ownership Reporting Requirements for Companies

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Earlier this year, Congress voted to override former President Trump’s veto of the 2021 National Defense Authorization Act (“NDAA”). The Corporate Transparency Act (“CTA”), enacted as part of the NDAA, requires “reporting...more

Polsinelli

Corporate Transparency Act – Your Beneficial Entity Ownership Disclosure Is Now Required

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Executive Summary - The U.S. Congress recently passed the Corporate Transparency Act (“CTA”) as part of the 2021 National Defense Authorization Act. The CTA requires certain corporations, limited liability companies and...more

Foodman CPAs & Advisors

Included in the AML ACT of 2020 is the Corporate Transparency Act which outlines Beneficial Ownership Reporting Requirements

The Corporate Transparency Act (CTA) is within the AML Act of 2020.  It establishes Beneficial Ownership Information Reporting Requirements to facilitate important national security, intelligence, and law enforcement...more

Ballard Spahr LLP

U.S. Passes Historic BSA/AML Legislative Change

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First Blog Post in an Extended Series on Legislative Changes to BSA/AML Regulatory Regime - Change is upon us. The U.S. House and Senate have passed – over a Presidential veto – the National Defense Authorization Act...more

Hogan Lovells

Treasury Department issues ransomware guidance in response to significant uptick in ransomware attacks

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In response to the significant rise in ransomware attacks since the start of the COVID-19 pandemic and just in time for Cybersecurity Awareness Month, the Department of the Treasury’s Financial Crimes Enforcement Network...more

White & Case LLP

FinCEN and US Federal Banking Agencies Clarify Risk-Based Obligations on Politically Exposed Persons

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The US Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies (Agencies)1 issued a joint statement on August 21, 2020, regarding Bank Secrecy Act/anti-money laundering (AML) regulatory requirements for...more

Ballard Spahr LLP

FinCEN Deputy Director Stresses Technological Innovation, Virtual Currency Enforcement and the U.S. Culture of Compliance

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Last Wednesday, FinCEN Deputy Director Jamal El-Hindi appeared at the annual conference of the Money Transmitter Regulators Association and delivered prepared remarks. The topics of his address covered three issues of...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

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