News & Analysis as of

Shell Corporations Suspicious Activity Reports (SARs)

Ballard Spahr LLP

FinCEN Renews and Expands GTO

Ballard Spahr LLP on

FinCEN announced on October 20 that, once again, it is extending the Geographic Targeting Order, or GTO, which requires U.S. title insurance companies to identify the natural persons behind so-called “shell companies” used in...more

BCLP

Second Economic Crime Bill heralds some big changes for financial services firms

BCLP on

We’ve waited over half a year for it and it’s finally here but what does the second Economic Crime and Corporate Transparency Bill of 2022 (the “Bill”) mean for businesses in and outside the regulated sector? The Bill’s...more

Orrick - Finance 20/20

FinCEN Urges Financial Institutions to Focus on Detecting Proceeds of Foreign Public Corruption

Orrick - Finance 20/20 on

The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more

Snell & Wilmer

New Year, New Laws – Congress Passes Major Anti-Money Laundering Act

Snell & Wilmer on

On January 1, 2021, Congress passed the National Defense Authorization Act for Fiscal Year 2021, an omnibus bill that includes the Anti-Money Laundering Act of 2020 (“AMLA”). The AMLA bans the use of anonymous shell companies...more

Eversheds Sutherland (US) LLP

Congress passes the Anti-Money Laundering Act of 2020, amending and modernizing the Bank Secrecy Act

On January 1, 2021, the US Senate voted to override President Donald Trump’s veto of H.R. 6395, the National Defense Authorization Act for Fiscal Year 2021 (NDAA). As part of the NDAA, the Anti-Money Laundering Act of 2020...more

King & Spalding

New BSA/AML Regime Promises Sweeping Changes

King & Spalding on

As we wrote over the summer, Congress has passed a bill that will require certain corporations and limited liability companies (“LLCs”) to report information on their beneficial owners to the U.S. Treasury Department’s...more

Eversheds Sutherland (US) LLP

The OCC’s 2019 annual report addresses anti-money laundering risks for financial institutions

The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more

Foley Hoag LLP - White Collar Law &...

U.S. Senate Considering Update to Federal Anti-Money Laundering System

A bipartisan group of Senators, with the support of the American Bankers Association, recently introduced bill S.2563, known as the ILLICIT Cash Act. The acronym “ILLICIT” stands for “Improving Laundering Laws and Increasing...more

Ballard Spahr LLP

FinCEN Issues Advisory on Human Rights Abuses Enabled by Corrupt PEPs and Their Financial Facilitators

Ballard Spahr LLP on

On June 12, 2018, FinCEN issued an “Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators” to highlight the connection between corrupt senior foreign political...more

Burr & Forman

Aloha Cash Buyers: FinCEN Issues Advisory to Financial Institutions; Expands Geographic Tracking Order to Include Honolulu, Wire...

Burr & Forman on

The Financial Crimes Enforcement Network (FinCEN) announced the revision of its Geographic Targeting Orders (GTO) Tuesday. The GTO requires title insurers to report beneficial ownership information on legal entities,...more

Foodman CPAs & Advisors

De-Risking 101

Foodman CPAs & Advisors on

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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