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Money Laundering Reporting Requirements BSA/AML

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

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

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The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...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

Kohn, Kohn & Colapinto LLP

FinCEN Head Praises New AML Whistleblower Program

The passage of the Anti-Money Laundering (AML) Whistleblower Improvement Act in December 2022 was heralded by whistleblower advocates as a major development which would transform the ability of the U.S. to crack-down on money...more

Falcon Rappaport & Berkman LLP

FinCEN’s Anti-Money Laundering Regulations for Residential Real Estate Transfers

To crack down on money-laundering in the U.S. residential real estate market, the Financial Crimes Enforcement Network (“FinCEN”) has proposed new reporting requirements for certain real estate transactions. Specifically, the...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

Mayer Brown

FinCEN Proposes New Residential Real Estate Reporting Requirements

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On February 7, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking on certain US residential real estate transactions (“2024 NPRM”). The 2024 NPRM...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

FinCEN Issues Final CTA BOI Access Rules, Heralded by YouTube Video

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This week, the Financial Crimes Enforcement Network (“FinCEN”) issued the much-anticipated final rule (“Final Rule”) under the Corporate Transparency Act (“CTA”) regarding access to beneficial ownership information (“BOI”)...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

Perkins Coie

AMLA 2020 Series Part 2: New Bank Secrecy Act Whistleblower Provisions

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On New Year’s Day 2021, Congress passed the Anti-Money Laundering Act of 2020 (AMLA 2020). As we reported last April, the AMLA 2020 included sweeping reforms aimed at strengthening protections against money laundering,...more

Perkins Coie

AMLA 2020 Series Part 1: New and Expansive Beneficial Ownership Reporting Requirements

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As we reported in April, the Anti-Money Laundering Act of 2020 (AMLA 2020) aims to strengthen protections against money laundering, terrorism financing, and other illegal activities through a variety of mechanisms, including...more

Foodman CPAs & Advisors

Incluida en la Ley ALD del 2020 está la Ley de Transparencia Corporativa, que describe los requisitos de informes sobre los...

La Ley de Transparencia Corporativa (“Corporate Transparency Act” – “CTA”) se encuentra dentro de la Ley ALD del 2020. Establece requisitos para la presentación de informes de información sobre los titulares reales para...more

Fuerst Ittleman David & Joseph

Anti-Money Laundering Compliance Game Changer: A series on the Anti-Money Laundering Act of 2020.

Part II: The Corporate Transparency Act and Beneficial Ownership Disclosure Requirements - On January 1, 2021, Congress overrode President Trump’s veto and passed the Anti-Money Laundering Act of 2020 (“AMLA”). The...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

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs

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As expected, on May 8, 2020, the Financial Crimes Enforcement Network (“FinCEN”) reissued its Geographic Targeting Orders (“GTOs”) requiring U.S. title insurance companies to identify the natural persons behind legal entities...more

Morrison & Foerster LLP

Financial Services Report, Fall 2019

We start this issue with a feeling of déjà vu all over again. Decisions made during the mortgage crisis are back in the news with a powerhouse legal ruling and the Treasury’s initial thinking on how to turn back time. First,...more

Foodman CPAs & Advisors

Content Matters in a Suspicious Activity Report (SAR)

The Suspicious Activity Report (SAR) was created by five federal financial agencies and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN)....more

Ballard Spahr LLP

Corporate Transparency Act of 2019 Broadens Beneficial Ownership Reporting

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In early March, the House Financial Services Committee released three proposed bills to codify many of the suggested reforms discussed during ongoing conversation among financial agencies, law enforcement, financial...more

Foodman CPAs & Advisors

A Quick Guide to the Suspicious Activity Report (SAR)

The Suspicious Activity Report (SAR) was originally created by five federal financial supervisory agencies (Federal Reserve Board, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Office of...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

Ballard Spahr LLP

Congress Contemplates Broad AML/BSA Reform

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As we blogged earlier this week, Congress is considering a new draft bill, the Counter Terrorism and Illicit Finance Act (“CTIFA”), in committee in the Senate.  The CTIFA proposes the most substantial overhaul to the Bank...more

Ballard Spahr LLP

Expanded Beneficial Ownership Reporting and AML Duties Under the Corporate Transparency Act

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Second of a Two-Part Blog: Anti-Money Laundering Programs Coming to the Legal Profession? Earlier this week, we began our discussion of the proposed Corporate Transparency Act of 2017 (the “Act”), and observed that, if...more

Ballard Spahr LLP

FinCEN Continues Its Focus on Real Estate Transactions through Advisory and GTOs

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FinCEN has announced the expansion of its Geographical Targeting Orders (GTOs) for high-end cash buyers of real estate. The expansion is two-fold. First, FinCEN has expanded the scope of Form 8300 reportable transactions to...more

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