News & Analysis as of

AML/CFT BSA/AML U.S. Treasury

Troutman Pepper

FinCEN Proposes Rule to Strengthen AML/CFT Programs

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On June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a proposed rule aimed at strengthening and modernizing financial institutions’ anti-money laundering and countering the...more

Ballard Spahr LLP

Treasury Issues RFI on Use of AI in Financial Services

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After several years of monitoring and reporting on artificial intelligence (AI) in financial services, the U.S. Department of Treasury (Treasury) has embarked on initial rulemaking efforts and issued a request for information...more

Ballard Spahr LLP

Treasury Issues Request for Information on Use of AI in Financial Services

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The U.S. Department of the Treasury (“Treasury”) has released a Request for Information on the Uses, Opportunities, and Risks of Artificial Intelligence (“AI”) in the Financial Services Sector (“RFI”).  Written comments are...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

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On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

White & Case LLP

FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs

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On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Ballard Spahr LLP

Department of Treasury Issues Strategy on De-Risking

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Report Offers Weak Insight on Causation but Lists Steps that Treasury Can and Should Take - The Department of Treasury (“DOT”) recently released its first ever strategy report (the “Strategy”) on the topic of de-risking,...more

Morrison & Foerster LLP

FinCEN Looks to Regulate the Real Estate Market

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On December 6, 2021, the Financial Crimes Enforcement Network (FinCEN) announced an Advance Notice of Proposed Rulemaking (ANPRM) to solicit comments in preparing a proposed rule that would increase transparency in the U.S....more

Foodman CPAs & Advisors

“Attachés” de la Tesorería, Enlaces de Unidades de Inteligencia Financiera Extranjera e Instituciones Financieras Extranjeras

La Ley ALD del 2020 (“AML Act of 2020”) incluye la creación de los “Attachés del Tesoro” (SEC. 6106, designados por el Departamento del Tesoro de los Estados Unidos) y los “Enlaces de la Unidad de Inteligencia Financiera...more

Foodman CPAs & Advisors

Treasury Attachés, Foreign Financial Intelligence Unit Liaisons and Foreign Financial Institutions

The AML Act of 2020 includes the creation of  “Treasury Attachés” (SEC. 6106, appointed by the US Treasury Department) and the “Foreign Financial Intelligence Unit Liaisons” (SEC. 6108, appointed by FinCEN) to be stationed...more

Foodman CPAs & Advisors

Bancos Extranjeros y el Nuevo Alcance de Brazo Largo del Tesoro de los EE. UU y el “DOJ”

Antes de la aprobación de la LEY AML del 2020 (“AML ACT of 2020”), el Departamento del Tesoro de los EE. UU. y el Departamento de Justicia de los EE. UU. (“DOJ”) tenían la autoridad para citar (“subpoena”) a los bancos...more

Foodman CPAs & Advisors

Foreign Bank and the New Longer Arm of the US Treasury and DOJ

Before passage of the AML ACT of 2020 (the “ACT”), The US Department of the Treasury, and the US Justice Department (DOJ) had US legal authority to subpoena foreign banks with US correspondent accounts for related US records...more

Foodman CPAs & Advisors

The U.S.A Continues to be AML/BSA “Vulnerable”

The U.S. Department of the Treasury 2020 Strategy (National Strategy for Combating Terrorist and Other Illicit Financing released on February 6, 2020) describes ongoing significant AML/CFT threats. ...more

Ballard Spahr LLP

Treasury Report Targets Money Laundering Risks in Real Estate and Gatekeeper Professions

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In its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”), the U.S. Department of Treasury (“Treasury”) has laid out its AML and money laundering enforcement priorities. Last week, we...more

Ballard Spahr LLP

Treasury Department’s 2020 National Illicit Finance Strategy: Aspirations for BSA/AML Modernization and the Combatting of Key...

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First in a Two-Post Series - The U.S. Department of Treasury (“Treasury”) has issued its 2020 National Strategy for Combating Terrorist and Other Illicit Financing (“2020 Strategy”)....more

Foodman CPAs & Advisors

What is Next after BSA turns 50?

On 2/6/2020, the U.S. Department of the Treasury issued the 2020 National Strategy for Combating Terrorist and Other Illicit Financing (2020 Strategy).  The purpose of the 2020 Strategy is to...more

Holland & Knight LLP

Treasury Releases 2020 National Strategy for Combating Terrorist and Other Illicit Financing

Holland & Knight LLP on

The 2020 National Strategy for Combating Terrorist and Other Illicit Financing was issued earlier this month by the U.S. Department of the Treasury. Prepared in consultation with regulators and law enforcement, including the...more

Foodman CPAs & Advisors

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more

Ballard Spahr LLP

Fact Sheet Clarifies AML/BSA Enforcement Priorities

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The U.S. Department of the Treasury and four U.S. federal banking regulators have issued the "Joint Fact Sheet on Foreign Correspondent Banking" in an effort to clarify enforcement priorities regarding Anti-Money Laundering...more

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