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Currency Transaction Reports (CTR)

Ballard Spahr LLP

FinCEN Issues Consent Order Against Card Club for “Fundamentally Unsound” AML Program

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The Financial Crimes Enforcement Network (“FinCEN”) has entered into a Consent Order with the Sahara Dunes Casino, doing business as the Lake Elsinore Hotel and Casino (“Lake Elsinore”).  The Consent Order describes Lake...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

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On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Seward & Kissel LLP

Q&A on FinCEN’s New AML Requirements for Certain Investment Advisers

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more

King & Spalding

FinCEN Issues Final Rule Expanding Anti-Money Laundering/ Countering the Financing of Terrorism Requirements for Investment...

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On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more

Ballard Spahr LLP

FinCEN Releases Year-in-Review for FY 2023: SARs, CTRs and Information Sharing

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The Financial Crimes Enforcement Network (“FinCEN”) has issued its Year in Review for FY 2023 (“YIR”). It consists of five pages of infographics. According to FinCEN’s press release...more

Foodman CPAs & Advisors

Tarjetas Pasaporte De EE.UU. – Aviso De FinCEN Sobre Fraude

El 15 de abril de 2024, FinCEN, junto con el Servicio de Seguridad Diplomática (“DSS”) del Departamento de Estado de EE.UU., emitió una advertencia sobre el fraude con tarjetas pasaporte de EE.UU. mediante un Aviso a las...more

Foodman CPAs & Advisors

U.S. Passport Card Fraud FinCEN Notice

On 4/15/24, FinCEN in conjunction with the U.S Department of State’s Diplomatic Security Service (DSS), issued warning regarding U.S. Passport Card Fraud via Notice to financial institutions urging them to be vigilant in...more

Ballard Spahr LLP

FinCEN Issues Notice on Counterfeit Passport Card Fraud

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The Financial Crimes Enforcement Network (“FinCEN”) has issued a Notice on the Use of Counterfeit U.S. Passport Cards to Perpetrate Identity Theft and Fraud Schemes at Financial Institutions (“Notice”), asking financial...more

Sherman & Howard L.L.C.

Alphabet Soup: FinCEN Proposal Would Add AML/CFT Obligations Under the BSA for RIAs & ERAs

Let me start by translating that headline to English. On February 15, 2024, the Financial Crimes Enforcement Network (FinCEN) division of the Department of Treasury issued a rule proposal that would require investment...more

King & Spalding

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

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The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

Ballard Spahr LLP

Criminal Case Round-Up: Recent Prosecutions Involving Financial Institution Officers

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The Department of Justice (“DOJ”) has been very active in the Bank Secrecy Act (“BSA”) / Anti-Money Laundering (“AML”) space, as reflected by a recent series of individual prosecutions and corporate non-prosecution agreements...more

Ballard Spahr LLP

FinCEN Issues Notice on Payroll Tax Evasion and Workers’ Compensation Fraud in the Construction Industry

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The Financial Crimes Enforcement Network (“FinCEN”) has issued a notice entitled “FinCEN Calls Attention to Payroll Tax Evasion and Workers’ Compensation Fraud in the Construction Sector” (the “Notice”). According to the...more

Ballard Spahr LLP

FinCEN Round Up:  FY 2022 in Review; First AML Enforcement Against a Trust Company; and Comments to Congress

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Last week, FinCEN “communicated,” so to speak, to private industry, law enforcement, regulators, and legislators in three very different ways: through a FY 2022 Year In Review infographic; a first-of-its kind enforcement...more

Foodman CPAs & Advisors

¿Cuándo Son Los Casinos Instituciones Financieras?

De acuerdo con el IRS y FinCEN, los casinos con licencia para hacer negocios como casinos y que tienen ingresos brutos anuales de juego superiores a $1,000,000 son instituciones financieras sujetas a los requisitos de la Ley...more

Foodman CPAs & Advisors

When Are Casinos Financial Institutions?

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According to the IRS and FinCEN, Casinos licensed to do business as casinos and which have gross annual gaming revenues in excess of $1,000,000 are Financial Institutions subject to the requirements of the Bank Secrecy Act,...more

J.S. Held

Decrypting Coinbase Accounts: A Guide for Forensic Analysts

J.S. Held on

As cryptocurrencies become more mainstream, it is vital for forensic analysts to understand and analyze digital currency data. Forensic analysts are increasingly being brought in to trace and help recover crypto assets in...more

Fenwick & West LLP

Section 987 Practice Unit Reflects a Permissive Attitude Towards Different Methods of Branch Currency Translation

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A few weeks ago, the IRS released a new “practice unit” providing training for its examiners on translation of foreign currency gains and losses of branches (so-called qualified business units, or QBU) under §987....more

Ballard Spahr LLP

AML Act Deadlines Through January 1, 2022 – A Daunting List

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The Financial Crimes Enforcement Network (“FinCEN”) recently complied with two important deadlines under the Anti-Money Laundering Act (“AML Act”) — issuing national priorities for AML and countering the financing of...more

K2 Integrity

Training and Developing a Culture of Compliance

K2 Integrity on

With tightening budgets, increasing regulatory expectations, and a growing number of risks, compliance teams at financial institutions face big challenges as they work to fulfill their mission to mitigate financial crimes and...more

Ballard Spahr LLP

As Treasury Eyes Crypto in Tax Compliance Agenda, Reporting Obligations May Increase – Including a Crypto “Form 8300” for...

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Treasury Offers Something for Everyone to Comply With: Trades and Businesses, Banks, Crypto Exchangers and Individuals - On May 21, 2021, the U.S. Department of Treasury (“Treasury”) released its American Families Plan Tax...more

Ballard Spahr LLP

Review, then Reform? AMLA Charts a Path for the Future of SARs and CTRs

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Eighth Blog Post in an Extended Series on Legislative Changes to the BSA/AML Regulatory Regime - As we have blogged, the Anti-Money Laundering Act of 2020 (“AMLA”) contains major changes to the Bank Secrecy Act (“BSA”),...more

Ballard Spahr LLP

“Real Housewives” Star Indicted for Money Laundering and Fraud

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The U.S. Attorney’s Office for the Southern District of New York announced the unsealing of a superseding indictment charging Jennifer Shah and another person for conspiring to commit wire fraud and money laundering. Shah,...more

Littler

Employment Law Implications of the New Anti-Money Laundering Act

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When Congress overrode President Trump’s veto of the National Defense Authorization Act on January 1, 2021, it enacted the Anti-Money Laundering Act (AMLA), which was part of the defense authorization bill.  In doing so,...more

Pierce Atwood LLP

Searching for Shells: New Federal Law Requires Privately-Held Companies to Disclose Ownership

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Tucked away in the recently-passed National Defense Authorization Act is the long-expected Anti-Money Laundering Act of 2020 (AMLA). The AMLA is the most significant update to anti-money laundering (AML) laws in the U.S. in...more

White & Case LLP

FinCEN’s proposed regulation of virtual assets

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A controversial proposed rule from the Financial Crimes Enforcement Network would bring bank-like regulation of virtual asset transactions, including the first broadly-applied AML reporting requirement in at least two...more

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