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National Security Customer Due Diligence (CDD)

Ballard Spahr LLP

Fifth Circuit Halts Nationwide Stay of CTA Enforcement

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The Fifth Circuit has granted the government’s request to stay temporarily the order and injunction issued by the United States District Court for the Eastern District of Texas, which had issued a nationwide stay prohibiting...more

WilmerHale

China Amends Its Anti-Money Laundering Law

WilmerHale on

China’s draft Amended Anti-Money Laundering (AML) Law1 (AML Law) was submitted to the Standing Committee of the National People's Congress (NPC) on September 10 for the second of what are generally three readings....more

Guidepost Solutions LLC

Emerging Expectations from the Latest Enforcement Actions Over Off-Channel Communications

Since December 2021, the U.S. Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) have levied almost $3.0 billion in penalties for longstanding failures by 39 broker-dealers, swap dealers,...more

Morrison & Foerster LLP

The Corporate Transparency Act: Access Rules

On December 21, 2023, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued final rules establishing a framework for accessing, using, and protecting beneficial ownership information (BOI)...more

Ballard Spahr LLP

Final CTA Access Rule Answers Some Questions, and Leaves Open Others

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The beneficial ownership information (“BOI”) registry under the Corporate Transparency Act (“CTA”) is now up and running at the Financial Crimes Enforcement Network (“FinCEN”). This post will follow up on a previous blog...more

Goodwin

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

Goodwin on

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

Oberheiden P.C.

OFAC Compliance: Avoiding Common Root Causes of Compliance Policy Breakdowns and Deficiencies

Oberheiden P.C. on

For financial institutions and businesses that are subject to the oversight of the Office of Foreign Assets Control (OFAC), compliance needs to be a priority in 2023. OFAC is playing an increasingly active role in overseeing...more

Holland & Knight LLP

FinCEN Releases Proposed Regulations for Accessing, Safeguarding Beneficial Owner Information

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) issued proposed regulations (Proposed Regulations) on Dec. 15, 2022, governing the disclosure, access and safeguarding of beneficial...more

King & Spalding

FinCEN Issues Final Rule for Beneficial Ownership Regulations

King & Spalding on

Implementation of Beneficial Ownership Reporting Obligations; Expanded CDD Rule Forthcoming On September 29, 2022, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Calls for Vigilance Against Anticipated Sanction Evasion Attempts

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert advising financial institutions to be vigilant against efforts to evade the expansive and unprecedented sanctions implemented by the United...more

Nutter McClennen & Fish LLP

The Corporate Transparency Act: FinCEN to Collect Beneficial Ownership Information

The Corporate Transparency Act (“CTA”) was enacted as part of the Anti-Money Laundering Act of 2020. The purpose of the CTA is to deter anonymous owners of corporations, limited liability companies, and other entities from...more

Polsinelli

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

Polsinelli on

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

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

White & Case LLP

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

White & Case LLP on

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

K2 Integrity

FinCEN’s Beneficial Ownership Rule and Increased AML Burden

K2 Integrity on

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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