Dually registered, or “dual hat,” investment advisers are already well aware of the extensive obligations imposed by the Bank Secrecy Act (“BSA”). But for others, the finalization of a Financial Crimes Enforcement Network...more
In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more
5/20/2024
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Broker-Dealer ,
Customer Identification Program (CIP) ,
Financial Institutions ,
Financial Regulatory Reform ,
FinCEN ,
Investment Adviser ,
NPRM ,
Popular ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs)
In its latest attempt, the U.S. Department of Treasury, Financial Crimes Enforcement Network (“FinCEN”), will require certain investment advisers to implement compliance measures to detect and report suspected money...more
As consumer-facing financial institutions of all types—from well-established banks to newly-launched fintechs—set their 2024 regulatory compliance goals, they may wonder if their New Year’s resolutions align with those that...more
1/12/2024
/ Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Cybersecurity ,
Due Diligence ,
Enforcement Actions ,
FDIC ,
Federal Reserve ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
FinCEN ,
Governance Standards ,
NYDFS ,
OCC ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
Regulatory Agenda ,
Remediation ,
Self-Reporting ,
Third-Party ,
UDAAP
With the start of the new year, FinCEN’s Beneficial Ownership Reporting Rule (BOI Reporting Rule) came into effect, implementing specific transparency requirements relating to corporate ownership. The BOI Reporting Rule...more
Shinhan Bank America (“Shinhan”), a New York-based subsidiary of a Korean bank, faced coordinated enforcement actions on September 29 from the Financial Crimes Enforcement Network (“FinCEN”), Federal Deposit Insurance...more
10/12/2023
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
Cryptoassets ,
Cryptocurrency ,
Enforcement Actions ,
FDIC ,
Financial Institutions ,
FinCEN ,
FinTech ,
New York ,
NYDFS