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What Is an “Effective AML/CFT Compliance Program”?

The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Corporate Transparency Act Midyear Update: Game-Changing FinCEN Guidance and What To Do To Meet Year-End Filing Obligations

June marked the six-month milestone for the implementation of the Corporate Transparency Act (CTA)—the landmark anti-money laundering law requiring beneficial ownership reporting for U.S. companies that became effective on...more

CTA Compliance Tip: Spouses and Domestic Partners in Community Property States May Also Be “Beneficial Owners”

As discussed in our prior Update on the Corporate Transparency Act (CTA), anyone who owns or controls at least 25% of the ownership interests of a CTA reporting company must report their beneficial ownership to the Financial...more

Corporate Transparency Act Will Require Disclosure of Senior Officers and Directors of Many US and Foreign Companies

The Corporate Transparency Act (CTA) became law on January 1, 2021, and requires companies formed and/or operating in the United States to disclose beneficial ownership information through a database that will be maintained...more

Think Public and Large Companies Are Entirely Exempt From the Corporate Transparency Act? Think Again.

Key portions of the Corporate Transparency Act (CTA) will take effect on January 1, 2024, requiring an estimated 30 million “reporting companies” to disclose to the federal government information and documentation about the...more

The Corporate Transparency Act: What To Know and Expect Starting January 1, 2024

Beginning January 1, 2024, the Corporate Transparency Act (CTA) will require most entities formed or registered to do business in the United States to disclose detailed information regarding their owners, officers, and...more

FFIEC BSA/AML Exam Manual Updates - Implications for Banks

The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more

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