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
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
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
On April 14, 2022, the Financial Crimes Enforcement Network (“FinCEN”) issued an advisory on kleptocracy and foreign public corruption. At a high level, the advisory stresses the importance of financial institutions focusing...more
On January 24, 2022, the Financial Crimes Enforcement Network (“FinCEN”) published a Notice of Proposed Rulemaking (“NPRM”). FinCEN is proposing a rule to establish a pilot program that permits certain financial institutions...more
In late October, the Financial Action Task Force issued its long-awaited updated guidance on Virtual Assets and Virtual Asset Service Providers (“FATF Guidance”), an extremely lengthy and detailed document setting forth how...more
Amicus Briefs Urge that Only FinCEN, Not the SEC, Should Enforce the BSA in Regards to Broker-Dealers -
In the next stage of the Alpine Securities saga (as we blogged about here, here and here), a petition for a writ of...more
Bottom Line: Biden Administration May Revive FinCEN’s Proposed Rule For Investment Advisers -
Unlike broker-dealers, investment advisers are not currently required to maintain anti-money laundering...more