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Reporting Requirements Suspicious Activity Reports (SARs) AML/CFT

K2 Integrity

Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now?

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On 15 January 2025, K2 Integrity hosted a webinar that featured Justina Rousseau, senior managing director at K2 Integrity; Aseel Rabie, counsel at Debevoise & Plimpton LLP; and Sarah Runge, executive managing director at K2...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

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On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

Eversheds Sutherland (US) LLP

FinCEN adopts investment adviser AML rules

The Financial Crimes Enforcement Network (FinCEN) adopted a final rule that adds most federal Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to the definition of “financial institution” under the...more

Ballard Spahr LLP

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

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The federal banking agencies, including the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the...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

Foodman CPAs & Advisors

Directora Gacki De FinCEN Fomenta La Transparencia En El Sistema Financiero De EE. UU

Durante la Conferencia Anual contra el Lavado de Dinero de FIBA (“Financial and International Business Association”) celebrada el 18 al 21 de marzo de 2024 en Miami, Florida, la Directora Gacki de FinCEN discutió las...more

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

Holland & Knight LLP

FinCEN Proposal for Nonfinanced Purchases of Residential Real Estate and Gratuitous Transfers

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...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

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

Goodwin

FinCEN Proposes AML Program Rule for Investment Advisers

Goodwin on

The Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Treasury Department, has issued a proposed rule (the “Proposal”) that would subject certain investment advisers to anti-money laundering (“AML”)...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules in Q1 2024

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

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The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

K2 Integrity

SEC Division of Examination Risk Alert Highlights Deficiencies in Broker-Dealers’ AML Compliance Programs

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The U.S. Securities and Exchange Commission (SEC) is responsible for protecting investors and ensuring the integrity of the securities markets. As part of this mission, the SEC requires broker-dealers to comply with...more

K2 Integrity

Human Trafficking and Banking: What Compliance Officers Need to Know

K2 Integrity on

Human trafficking is a global crisis that has an impact on lives around the globe. Over time, there have been many initiatives taken by governments and nonprofits to identify and help victims while promoting enhanced...more

Ballard Spahr LLP

FinCEN Seeks Industry Comments on SAR Reporting Burden and Provides Plentiful SAR Stats

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Federal Register Notice Implicates Debate Over BSA Reporting Burden - As we have blogged, the Financial Crimes Enforcement Network (“FinCEN”) consistently has stressed the importance of Suspicious Activity Reports (“SARs”)...more

K2 Integrity

Is Your AML Program Up to the Task?

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Fulfilling today’s requirements for anti-money laundering and counterterrorism financing/sanctions compliance is no easy task for financial institutions. ...more

Foodman CPAs & Advisors

De-Risking 101

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Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

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