On June 28, 2024, The U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (the “Proposed Rule”) that would amend FinCEN’s anti-money laundering (“AML”) program rules for...more
On March 1, 2024, the U.S. District Court for the Northern District of Alabama ruled that the Corporate Transparency Act (“CTA”) is unconstitutional. The CTA requires many U.S. entities to disclose their individual beneficial...more
3/25/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
Commerce Clause ,
Congressional Authority ,
Constitutional Challenges ,
Corporate Transparency Act ,
FinCEN ,
Motion To Enjoin ,
National Security ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Evasion ,
U.S. Treasury
On February 15, the U.S. Treasury’s Financial Crimes Enforcement Network (“FinCEN”), published a proposed rule that would define specified investment advisers as “financial institutions” required to implement anti-money...more
2/26/2024
/ Anti-Money Laundering ,
BSA/AML ,
Customer Due Diligence (CDD) ,
Customer Identification Program (CIP) ,
Financial Crimes ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Investment Adviser ,
Proposed Rules ,
Regulatory Agenda ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
On December 21, 2023, the Financial Crimes Enforcement Network (“FinCEN”) published its final rule setting forth the circumstances under which beneficial ownership information reported to FinCEN pursuant to the Corporate...more
2/9/2024
/ Anti-Corruption ,
Anti-Money Laundering ,
Beneficial Owner ,
BSA/AML ,
Corporate Transparency Act ,
Final Rules ,
Financial Crimes ,
Financial Institutions ,
FinCEN ,
Ownership Interest ,
Regulatory Requirements ,
Reporting Requirements
U.S. regulators are signaling heightened expectations for anti-money laundering compliance within the crypto industry. Although FinCEN issued guidance in 2013 interpreting virtual currency “administrators” and “exchanges” as...more
1/20/2023
/ AML/CFT ,
Anti-Money Laundering ,
BSA/AML ,
Cryptocurrency ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinCEN ,
Money Services Business ,
Popular ,
Proposed Legislation ,
Regulatory Agenda
On July 6, five federal agencies − the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation (“FDIC”), Financial Crimes Enforcement Network (“FinCEN”), National Credit Union...more