News & Analysis as of

Anti-Money Laundering Public Comment

Cranfill Sumner LLP

FinCEN Is Engaged in Rulemaking to Modernize Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) Programs;...

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On June 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued proposed rules to modernize and improve financial institutions’ anti-money laundering and countering the financing...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Latham & Watkins LLP

FDIC Proposes Revisions to Policy on Bank Merger Transactions

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The Proposal clarifies the FDIC’s bank merger approval process but may prove challenging for new large bank consolidations with the FDIC as the primary regulator. On March 21, 2024, the Board of Directors of the Federal...more

ArentFox Schiff

Calling all Cash Money Millionaires: FinCEN Proposes New Reporting Rules for Cash Residential Real Estate Transfers

ArentFox Schiff on

“In residential real estate sales, all parties involved, including sellers, developers, title companies, attorneys, and closing agents, need to be aware of reporting requirements. Consider a situation where a commercial...more

K2 Integrity

[Webinar] Implications of FinCEN's Notice of Proposed Rulemaking on Virtual Currency Mixers - January 17th, 9:00 am PT

K2 Integrity on

Join K2 Integrity Global Co-managing Partner and Chief Strategy Officer Juan Zarate and Coinbase Global Head of Financial Crimes Compliance Valerie-Leila Jaber for a discussion of FinCEN’s notice of proposed rulemaking on...more

Patterson Belknap Webb & Tyler LLP

FinCEN Issues Notice of Proposed New Beneficial Ownership Information Reporting Requirements Under the Corporate Transparency Act

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the United States Department of the Treasury, published a Notice of Proposed Rulemaking (the “Proposed Rules”) on December 8, 2021 in the Federal Register. The...more

Blank Rome LLP

[Webinar] New Corporate Transparency Rules Taking Shape: What Should Businesses Expect? - February 2nd, 12:30 pm - 1:00 pm ET

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For the first time in decades, Congress in 2021 enacted major reform to anti-money laundering laws. A central piece of this legislation was the Corporate Transparency Act, which promised to increase companies’ obligations to...more

Kramer Levin Naftalis & Frankel LLP

Corporate Governance 2021 Year in Review (and a First Look at 2022)

2021 was a busy year for corporate governance matters, with new legislation passed early in the year and new enforcement priorities emerging under the Biden administration. Kramer Levin lawyers published numerous articles...more

Goodwin

FinCEN Proposes Rules Implementing Corporate Ownership Requirements Under Corporate Transparency Act to Fill Gaps in U.S....

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WHAT YOU NEED TO KNOW: - The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule to implement portions of the Corporate Transparency Act codified at 31 U.S.C. § 5336 (CTA). ...more

Holland & Knight LLP

FinCEN Seeks Public Input to Reduce Vulnerability of Real Estate Market to Money Laundering

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The Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (Notice) on Dec. 9, 2021, requesting public comment on ways to enhance the transparency of the domestic real estate market...more

Kramer Levin Naftalis & Frankel LLP

FinCEN Considers New Anti-Money Laundering Reporting Requirements For All-Cash Real Estate Transactions

The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a proposed rule that would address the...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

Goodwin on

In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Goodwin

Supreme Court Decision Empowers President Biden to Replace Director of FHFA

Goodwin on

In This Issue. In a move that gives him the opportunity to put his stamp on housing policy and the potential overhaul of Fannie Mae and Freddie Mac, President Biden replaced the Director of the Federal Housing Finance Agency...more

McDermott Will & Emery

[Ongoing Program] Japan Webinar Series - Session 4: Trade Policy Outlook - June 3rd, 11:00 am - 12:00 pm JST

McDermott Will & Emery on

McDermott is committed to provide insightful legal developments around the world to our Japanese clients. In light of that effort, Japan Webinar Series will be held between Thursday, May 20 – Thursday, June 3, 2021. This...more

McDermott Will & Emery

[Ongoing Program] Japan Webinar Series - Session 3: Global Internal Investigations - June 1st, 11:00 am - 12:00 pm JST

McDermott Will & Emery on

McDermott is committed to provide insightful legal developments around the world to our Japanese clients. In light of that effort, Japan Webinar Series will be held between Thursday, May 20 – Thursday, June 3, 2021. This...more

McDermott Will & Emery

[Ongoing Program] Japan Webinar Series - Session 2: Compliance: How Will The United States DOJ View Your Compliance Program, And...

McDermott Will & Emery on

McDermott is committed to provide insightful legal developments around the world to our Japanese clients. In light of that effort, Japan Webinar Series will be held between Thursday, May 20 – Thursday, June 3, 2021. This...more

McDermott Will & Emery

[Ongoing Program] Japan Webinar Series - Session 1: Global Antitrust Developments - May 20th, 11:00 am - 12:00 pm JST

McDermott Will & Emery on

McDermott is committed to provide insightful legal developments around the world to our Japanese clients. In light of that effort, Japan Webinar Series will be held between Thursday, May 20 – Thursday, June 3, 2021. This...more

Goodwin

Fed Proposes Guidelines for Access to Master Accounts and Payment Services

Goodwin on

In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve), in response to an increased number of inquiries and access requests from companies with fintech and other narrow purpose charters, invited...more

Bilzin Sumberg

FinCEN Seeks Public Comment on Corporate Transparency Act

Bilzin Sumberg on

On April 1, 2021, the Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (the "Notice") seeking public comment on a myriad of issues related to the implementation of a beneficial...more

Goodwin

SEC Raises Concerns About Misleading ESG Practices, Highlights Potential Violations

Goodwin on

In This Issue. The U.S. Securities and Exchange Commission (SEC) Division of Examinations issued a Risk Alert raising concerns about misleading Environmental, Social, and Governance (ESG) disclosures by investment firms; the...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

Goodwin on

In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

King & Spalding

Pumping the Brakes: FinCEN Reopens Comment Period for Controversial Crypto Reporting & Recordkeeping Rules

King & Spalding on

After Widespread Market Opposition in an Expedited First Round of Comments, FinCEN Solicits More Feedback on Rule Seeking to “Close Gaps” in Virtual Currency Anti-Money Laundering Rules On January 14, in a surprise move,...more

White & Case LLP

FinCEN Invites Comments on Anti-Money Laundering Program Effectiveness

White & Case LLP on

On September 16, the US Financial Crimes Enforcement Network (FinCEN) issued an advance notice of proposed rulemaking (ANPRM) seeking to update the US anti-money laundering (AML) regime. This is an historic opportunity for...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Seeks Public Comment on Proposed Changes to Regulations Enforcing the Bank Secrecy Act

Anti-money laundering authorities are proposing a significant revision to the federal AML regulatory scheme with the aim of making it more effective while providing greater clarity to covered institutions. ...more

Goodwin

Federal Reserve Proposes Rules To Modernize Regulations That Implement CRA

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In the News. The Board of Governors of the Federal Reserve System (Federal Reserve) proposed rules to modernize the regulations that implement the Community Reinvestment Act (CRA); the Conference of State Bank Supervisors...more

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