News & Analysis as of

NPRM Financial Crimes

Clark Hill PLC

Prudential Regulators Propose Rules Amending Anti-Money Laundering Requirements: Is Your Financial Institution Ready?

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On July 14, the Financial Crimes Enforcement Network (FinCEN) joined the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of...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

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...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

Jones Day

FinCEN Issues Final Rule Extending Beneficial Ownership Information Reporting Deadline for New Entities

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The Financial Crimes Enforcement Network ("FinCEN") has issued a final rule ("Final Rule") extending the initial reporting deadline for new entities required to file beneficial ownership information ("BOI") with FinCEN to 90...more

Foodman CPAs & Advisors

ALD/FT Viene A Los “Investment Advisers”

El 15 de febrero de 2024, FinCEN publicó un Aviso de Reglamentación Propuesta (NPRM) que requeriría que ciertos asesores de inversiones (Investment Advisers) apliquen requisitos de ALD/FT conforme con la Ley de Secreto...more

Foodman CPAs & Advisors

AML/CFT Coming To Investment Advisers

On 2/15/24, FinCEN published a Notice of Proposed Rulemaking (NPRM) that would require certain investment advisers to apply AML/CFT requirements pursuant to the Bank Secrecy Act, including implementing risk-based AML/CFT...more

Foodman CPAs & Advisors

Reporte Real Estate De FinCEN

El 7 de febrero de 2024, FinCEN emitió un Aviso de Reglamentación Propuesta (NPRM) para combatir y disuadir el lavado de dinero en el sector inmobiliario residencial de EE. UU. mediante el aumento de la transparencia. FinCEN...more

Foodman CPAs & Advisors

Real Estate Report From FinCEN

On February 07, 2024, FinCEN issued a Notice of Proposed Rulemaking (NPRM) to combat and deter money laundering in the U.S. residential real estate sector by increasing transparency. FinCEN is seeking to require certain...more

Ballard Spahr LLP

FinCEN Proposes BSA Reporting Requirements for Residential Real Estate

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On February 16, the Financial Crimes Enforcement Center (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) regarding residential real estate. The final version of the NPRM published in the Federal Register is 47...more

Troutman Pepper

FinCEN Proposes Extending AML/CFT Requirements to Certain Investment Advisors

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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

Polsinelli

Part 3: Addressing and Demystifying Common Denials Surrounding the Upcoming CTA

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CTA Denial #3: “My industry’s lobbyists would never allow such a law to get passed.” Lobbyists had staved off attempts to implement the CTA, and its predecessor bills, for decades....more

Womble Bond Dickinson

Explaining the New Corporate Transparency Act

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Beginning January 1, 2024, domestic entities and foreign entities registered to do business in the United States will need to comply with new information reporting requirements relating to their owners, officers, and...more

Bilzin Sumberg

The Corporate Transparency Act: Is it Really Happening?

Bilzin Sumberg on

The U.S. government just averted a government shutdown this past Saturday (or at least punted for another 45 days). In the last three weeks all signals from the Financial Crimes Enforcement Network (“FinCEN”) suggests the...more

Schwabe, Williamson & Wyatt PC

Corporate Transparency Act: Reporting Beneficial Ownership Starting January 2024

On January 1, 2024, the Corporate Transparency Act (the “Act” or the “CTA”) will go into effect. It is expected to impact approximately 32.6 million small and medium-sized businesses in unregulated industries in its first...more

Orrick, Herrington & Sutcliffe LLP

CSBS says state regulators need access to FinCEN’s beneficial ownership database

On February 14, the Conference of State Bank Supervisors commented that FinCEN should be more explicit in its inclusion of state regulators as agencies that can request access to FinCEN’s forthcoming secure, non-public...more

Bilzin Sumberg

Key Updates in the Transparency World for Private Clients

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FinCEN Proposes the Second Installment to the Corporate Transparency Act - On December 15, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (the "Notice") in relation to the...more

Williams Mullen

FinCEN’s Proposed Rule: The Who, What and When of Beneficial Ownership Reporting under the CTA

Williams Mullen on

In December 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (the Proposed Rule) to implement the beneficial ownership reporting requirements of...more

Foodman CPAs & Advisors

¿Cómo implementará FinCEN las Provisiones de Reportaje de Información de los Dueños Beneficiarios de la Ley de Transparencia...

FinCEN ha estado ocupada en la búsqueda de combatir la corrupción, como lo demuestra la emisión consecutiva de Avisos de Propuesta de Reglamentación (“NPRMs”). El 6/12/21, emitieron el (Proceso regulatorio para los nuevos...more

Foodman CPAs & Advisors

How will FinCEN Implement the Beneficial Ownership Information Reporting Provisions of the Corporate Transparency Act (CTA)? They...

FinCEN has been busy in the quest to fight corruption as evidenced by back-to-back issuance of Notices of Proposed Rulemaking (NPRMs).  On 12/6/21, they issued the (Regulatory Process for New Real Estate Sector Reporting...more

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Notice of Proposed New Beneficial Ownership Information Reporting Requirements Under the Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, published a Notice of Proposed Rulemaking (the “Proposed Rules”) on December 8, 2021 in the Federal Register. The...more

Burr & Forman

FinCEN Issues Proposed Beneficial Ownership Reporting Rules to the Corporate Transparency Act

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Background and Development - On December 7, 2021, the Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”) for the Corporate Transparency Act (the “CTA”).  ...more

BCLP

FinCEN’S Broad Proposed Beneficial Ownership Reporting Requirements - Targeting “terrorists, criminals and kleptocrats”

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Today’s proposed rule will greatly expand the application of reporting requirements identifying the true owners of business entities formed under U.S. law or formed under foreign laws and registered to do business in the...more

Bilzin Sumberg

FinCEN Seeks Public Comment on Corporate Transparency Act

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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

Morgan Lewis

FinCEN Releases Advance Notice of Proposed Rulemaking on New Beneficial Ownership Reporting Requirement

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The US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on April 1 took the first step towards implementing the Corporate Transparency Act’s (CTA’s) beneficial ownership reporting requirements,...more

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