News & Analysis as of

Terrorist Financing Regulations Customer Due Diligence (CDD)

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

Troutman Pepper

FinCEN Proposes Rule to Strengthen AML/CFT Programs

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On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Ballard Spahr LLP

Recent FDIC consent orders show increased regulation scrutiny of bank relationships with fintech partners

Ballard Spahr LLP on

In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...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

Buchalter

Congress Makes Sweeping Changes to Money Laundering Enforcement

Buchalter on

On New Year’s Day 2021, Congress passed—over President Trump’s veto—a defense appropriations law containing the Anti-Money Laundering Act of 2020 (“AML Act”) and the Corporate Transparency Act, as part of a sweeping new set...more

Ballard Spahr LLP

FinCEN Issues New FAQs on CDD Rule

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On Monday, the Financial Crimes Enforcement Network (FinCEN) issued new Frequently Asked Questions (FAQs) regarding customer due diligence (CDD) requirements for covered financial institutions. The FAQs supplement FinCEN’s...more

K2 Integrity

FATF Upgrades U.S. Customer Due Diligence Regime

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On March 31st the Financial Action Task Force (FATF)—the global AML/CFT standard-setting body and watchdog—announced that it has upgraded the United States for technical compliance with FATF Recommendation 10 following...more

A&O Shearman

UK Secondary Legislation Published Implementing EU Fifth Money Laundering Directive

A&O Shearman on

The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 have been published, amending the existing Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The...more

BCLP

Additional Compliance for the Art World

BCLP on

Individuals, trusts and companies buying or selling art via UK galleries and auction houses will now be subject to the same customer due diligence checks as those opening bank accounts in the UK. What has changed? The...more

K2 Integrity

China Emerging as an Increasing Driver of Global Illicit Finance Risk

K2 Integrity on

Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more

Ballard Spahr LLP

The Fifth Anti-Money Laundering Directive: Extending the Scope of the European Union’s Regulatory Authority to Virtual Currency...

Ballard Spahr LLP on

On April 19, 2018, the European Parliament (“EP”) adopted the European Commission’s (the “Commission”) proposal for a Fifth Anti-Money Laundering Directive (“AMLD5”) to prevent terrorist financing and money laundering through...more

A&O Shearman

Implementation of the fourth AML directive in Luxembourg: what will be the new obligations?

A&O Shearman on

The Luxembourg Parliament has now finally adopted bill n° 71281, which implements most of the provisions of the Directive (EU) 2015/849, the so-called 4th anti-money laundering directive (AMLD IV), into Luxembourg law. The...more

Ballard Spahr LLP

Congress Proposes National Directory of Beneficial Owners of Legal Entities

Ballard Spahr LLP on

Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), currently in committee in the Senate.  The CTIFA proposes the most substantial overhaul to the Bank Secrecy Act (“BSA”) since...more

Dechert LLP

Financial Services Quarterly Report - Fourth Quarter 2017: Developments in the Luxembourg Financial Sector

Dechert LLP on

Luxembourg recently published two important bills to combat money laundering and terrorism financing – one transposes the EU AML4 Directive1 into Luxembourg law; the second establishes a central register of beneficial owners,...more

Moore & Van Allen PLLC

Anti-Money Laundering and Bank Secrecy Act Update

Moore & Van Allen PLLC on

After the Panama Papers exposed efforts by wealthy individuals and government officials to hide funds offshore, government authorities around the world have responded with new legislation, regulations and enforcement actions...more

Pillsbury - Global Trade & Sanctions Law

EU Proposes Significant Changes to Anti-Money Laundering Laws

Policy makers in Europe continue to explore responses to the Panama Papers revelations and recent terrorist attacks. On 28 February, European law makers approved important amendments to the EU’s Anti-Money Laundering (AML)...more

A&O Shearman

European Banking Authority Opines on Virtual Currencies and the Fourth Anti-Money Laundering Directive

A&O Shearman on

The European Banking Authority published an Opinion on the Commission’s proposed amendments to the Fourth Anti-Money Laundering Directive and its application to virtual currencies. The Commission is proposing to bring...more

Foodman CPAs & Advisors

Why is On-boarding and Off-boarding Bank Clients Important?

After the Panama Papers, and with the recent FinCEN final Customer Due Diligence (CDD) rule, U.S. financial institutions are further focused on tightening internal controls against money laundering, terrorist financing,...more

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