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FinCEN Issues Reminder to Financial Institutions to Identify and Report Elder Financial Exploitation

On June 14, 2024, President Biden declared June 15th World Elder Abuse Awareness Day.  In honor of the day, the Financial Crimes Enforcement Network (FinCEN) reminded financial institutions (FIs) to remain vigilant in...more

Beneficial Ownership Reporting is Coming for Millions of Companies

Summary - On September 30, 2022, the Financial Crimes Enforcement Network (FinCEN), a unit of the U.S. Department of Treasury, issued its final rule, Beneficial Ownership Information Reporting Requirements (Final Rule),...more

FinCEN Final Rule for Beneficial Ownership Reporting: The “Substantial Control” Prong

Second Post in a Two-Post Series on the CTA Implementing Regulations - As we just blogged, the Financial Crimes Enforcement Network (“FinCEN”) has issued a final rule (“Final Rule”) regarding the beneficial ownership...more

FinCEN Issues Final Rule on Beneficial Ownership Reporting Requirements

First Post in a Two-Post Series on the CTA Implementing Regulations - On September 30, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued its final rule, Beneficial Ownership Information Reporting...more

Proposed Beneficial Ownership Reporting Regulations Under the CTA:  Broad and Complex

As we initially blogged, the Financial Crimes Enforcement Network (“FinCEN”) issued on December 7 a Notice of Proposed Rulemaking (“NPRM”) regarding the beneficial ownership (“BO”) reporting requirements of the Corporate...more

Corporate Transparency Act of 2019 Broadens Beneficial Ownership Reporting

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

FinCEN Issues Exceptive Relief from Beneficial Ownership Rule to Certain Account Renewals

FinCEN Cites Low Risk of Money Laundering and High Regulatory Burden of Rule - On September 7, 2018, the Financial Crimes Enforcement Network (“FinCEN”) issued permanent exceptive relief (“Relief”) to the Beneficial...more

Just How Safe Is the SAR Safe Harbor Provision?

Congress enacted the safe harbor provision of the Bank Secrecy Act (BSA), codified at 31 U.S.C. §5318(g)(3)(A), to shield financial institutions, their officers and employees from civil liability for reporting known or...more

FinCEN’s Beneficial Ownership Rule: More Practical Tips and Answers to Frequently Asked Questions

Last year, we posted FinCEN’s Beneficial Ownership Rule: A Practical Guide to Being Prepared for Implementation regarding the Customer Due Diligence Requirements for Financial Institutions Rule (the “Beneficial Ownership...more

The Definition of a Whistleblower Under the Dodd-Frank Act is Shrinking

In a unanimous ruling on February 21, the U.S. Supreme Court narrowed the definition of a whistleblower under the Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act)....more

FinCEN Expands Targeting of High-End Cash Real Estate Transactions

FinCEN has announced a major expansion and extension of its geographic targeting orders (GTOs) aimed at high-end cash buyers of real estate. This action reflects FinCEN’s continued efforts to prevent money laundering through...more

NYDFS Finalizes AML/BSA Regulation

The New York Department of Financial Services (DFS) has finalized a new regulation setting rigorous standards for monitoring and filtering programs to monitor transactions for potential anti-money laundering (AML) and Bank...more

FinCEN Finalizes Beneficial Ownership Identification Rules

As part of the U.S. Treasury Department's ongoing efforts to prevent bad actors from using U.S. companies to conceal money laundering, tax evasion, and other illicit financial activities, the Financial Crimes Enforcement...more

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