James Mangiaracina

Ballard Spahr LLP

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Bank Industry Groups Heavily Criticize FinCEN’s Proposed Rule on Access to Beneficial Ownership Information

On February 14, 2023, both the American Bankers Association (ABA) and the Bank Policy Institute (BPI) submitted comments to the Financial Crimes Enforcement Network (FinCEN) on FinCEN’s notice of proposed rulemaking (NPRM)...more

3/6/2023  /  Banking Sector , Banks , Beneficial Owner , FinCEN , Proposed Rules

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

10/11/2022  /  Beneficial Owner , Corporate Transparency Act , Customer Due Diligence (CDD) , Final Rules , Financial Institutions , FinCEN , Reporting Requirements

Closing the Gate—House Adopts ENABLERS Act Amendment to 2023 NDAA

Amendment Focuses on Professional “Gatekeepers” – Lawyers, Accountants, Payment Processors, and Those Providing Corporate Formation and Trust Services - On July 13, 2022, the House of Representatives (the “House”) adopted...more

7/21/2022  /  Anti-Money Laundering , Bank Secrecy Act , Beneficial Owner , Financial Institutions , FinCEN , NDAA , Suspicious Activity Reports (SARs)
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