On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a rule to require reporting of certain US residential real estate transactions (“Final Rule”). The Final Rule...more
On June 28, 2024, the US Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (“June 2024 NPRM”) to crystalize its long-held expectation that financial institutions use...more
On July 8, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued interpretive guidance explaining that the beneficial ownership information (“BOI”) reporting requirement applies to certain legal entities that have...more
I. INTRODUCTION -
On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more
5/31/2024
/ Anti-Money Laundering ,
Compliance ,
Exempt Reporting Advisers (ERAs) ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
NPRM ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC)
On April 18, 2024, the Financial Crimes Enforcement Network (“FinCEN”) announced its revised implementation schedule for providing access to the beneficial ownership information (“BOI”) reports. The tentative, revised...more
On March 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), in consultation with the staffs of the federal banking agencies, issued a request for information and comment (the “RFI”)...more
On March 1, 2024, the US District Court for the Northern District of Alabama declared the Corporate Transparency Act (“CTA”) unconstitutional, and suspended its enforcement against the plaintiffs in that case. While most...more
3/7/2024
/ Beneficial Owner ,
Commerce Clause ,
Compliance ,
Constitutional Challenges ,
Corporate Transparency Act ,
FinCEN ,
Injunctions ,
National Security ,
NSBA ,
Reporting Requirements ,
Small Business ,
Summary Judgment
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
On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more
2/16/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Money Laundering ,
Popular ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On January 29, 2024, the US Department of Commerce’s Bureau of Industry and Security (the “Department”) issued a notice of proposed rulemaking seeking comment on a proposed regulation in response to the Executive Order (E.O.)...more
2/15/2024
/ Artificial Intelligence ,
Bureau of Industry and Security (BIS) ,
Cloud Computing ,
Comment Period ,
Customer Identification Program (CIP) ,
Cybersecurity ,
Executive Orders ,
Financial Institutions ,
IaaS ,
Machine Learning ,
National Security ,
NPRM ,
Proposed Regulation ,
U.S. Commerce Department
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) released a final rule to implement the beneficial ownership information (“BOI”) access requirements of the Corporate Transparency Act (“CTA”) (the...more
12/29/2023
/ Anti-Money Laundering ,
Beneficial Owner ,
Corporate Transparency Act ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Popular ,
Regulatory Requirements ,
Reporting Requirements