News & Analysis as of

Anti-Money Laundering › Beneficial Owner › Customer Identification Program (CIP)

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

Skadden, Arps, Slate, Meagher & Flom LLP on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

Pillsbury Winthrop Shaw Pittman LLP on

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Ballard Spahr LLP

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

Ballard Spahr LLP on

Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...more

Neal, Gerber & Eisenberg LLP

Treasury Proposes Regulations That Would Require Private Trust Companies to Establish or Enhance AML Programs and to Identify...

Neal, Gerber & Eisenberg LLP on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published proposed regulations on August 25, 2016 that would require certain private trust companies utilized by high net worth individuals,...more

A&O Shearman

FinCEN Issues Final Beneficial Owner Identification Rules

A&O Shearman on

In May 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network issued final rules regarding beneficial owner identification obligations for legal entity customers (the “Rule”). Under the Rule, covered...more

WilmerHale

Anti–Money Laundering Alert: FinCEN Finalizes Beneficial Ownership and Customer Due Diligence Requirements

WilmerHale on

The Financial Crimes Enforcement Network (FinCEN) on May 11 released its long-awaited Final Rule (CDD Rule) that will require certain financial institutions to “look through” the nominal account holder to identify the...more

Goodwin

FinCEN Issues Final Customer Due Diligence Rule

Goodwin on

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has expanded the due diligence obligations of certain financial institutions that are subject to a customer identification program requirement under...more

Eversheds Sutherland (US) LLP

FinCEN Customer Due Diligence Final Rules

Eversheds Sutherland (US) LLP on

On May 5, 2016, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued final rules (the Final Rules) on customer due diligence requirements for banks, securities broker-dealers, mutual funds, and...more

Stinson LLP

New FinCEN Rule Requires Heightened Identification Procedures and Anti-Money Laundering Diligence

Stinson LLP on

A new Financial Crimes Enforcement Network (FinCEN) rule under the Bank Secrecy Act will require institutions to more specifically identify legal entity customers and increase anti-money laundering diligence. The rule will...more

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