News & Analysis as of

Beneficial Owner Money Laundering Regulatory Requirements

Walkers

Update on changes to the beneficial ownership regime in the Cayman Islands

Walkers on

Changes to the beneficial ownership regime took effect on 31 July 2024 and enforcement relating to the new requirements is suspended until early 2025. Many entities that previously had few or no obligations will have to...more

Ruder Ware

The CTA’s Large Operating Company Exemption in Focus

Ruder Ware on

The Corporate Transparency Act (the “CTA”), part of the federal government’s effort to curtail money laundering by means of shell company structures, imposes disclosure requirements on most entities registered to do business...more

Cadwalader, Wickersham & Taft LLP

FinCEN's Proposed Streamlined SAR -- The Real Estate Report

On February 16, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule addressing “Anti-Money Laundering Regulations for Residential Real Estate Transfers.” The proposed rule would, among other...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

Stinson LLP on

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

Polsinelli

Addressing and Demystifying Common Denials Surrounding the Upcoming CTA: Part 1

Polsinelli on

CTA Denial #1: “I am a sophisticated business owner, and I have never heard of this.” The enactment of the CTA in 2021 came as a shock to many (to some, a much later aftershock)....more

Foster Swift Collins & Smith

Corporate Transparency Act: What You Need to Know Before 2024

Introduction and Scope of New Rule - With a stated goal of countering money laundering, the financing of terrorism and other illicit activities (including those of Russian oligarchs currently under U.S. sanctions),...more

Stikeman Elliott LLP

Ontario’s New Transparency Register: Getting Your OBCA Corporation Ready for January 1, 2023

Stikeman Elliott LLP on

Under new rules in force as of January 1, 2023, private corporations incorporated or continued under Ontario’s Business Corporations Act (“OBCA”) will be required to maintain a register (“Transparency Register”) of...more

Dechert LLP

FinCEN Corporate Transparency Proposed Regulations: Beneficial Ownership Information Reporting Requirements and the Potential...

Dechert LLP on

On December 7, 2021, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed new regulations (“Proposed Regulations”) defining and implementing the beneficial ownership reporting...more

Cohen & Gresser LLP

Pulling Back the Curtain: Congress Establishes a Beneficial Ownership Registry for U.S. and Foreign Businesses

Cohen & Gresser LLP on

On January 1, 2021, Congress overrode President Trump’s veto, passing into law the annual National Defense Authorization Act for Fiscal Year 2021 (“NDAA”). ...more

Ballard Spahr LLP

FinCEN Stresses Transparency, BSA Filing Data, and Perils of “Under- Regulating” to Securities Industry

Ballard Spahr LLP on

Last Thursday, FinCEN Deputy Director Jamal El-Hindi appeared at the 20th annual Anti-Money Laundering (AML) and Financial Crimes Conference hosted by the Securities Industry and Financial Markets Association (SIFMA) in New...more

Ballard Spahr LLP

Shell Company Update: Congress and FATF Target Beneficial Ownership

Ballard Spahr LLP on

U.S. House Passes Corporate Transparency Act; FATF Issues Guidance on Identifying Entities’ Beneficial Owners - First Post in a Two-Post Series on Beneficial Ownership - As we often blog, the issue of the beneficial...more

Ballard Spahr LLP

Lawmakers Renew Effort to Overhaul AML Laws, Including Greater Beneficial Ownership Transparency

Ballard Spahr LLP on

The Issue of Who Truly Runs and Owns Entities Contines to Gnaw at Congress and Law Enforcement - First Post in a Two-Post Series on the ILLICIT CASH Act - On June 10, a bipartisan group of lawmakers in the U.S. Senate...more

Ballard Spahr LLP

FinCEN Renews Real Estate GTOs: Expanded Geographic Coverage and Reduced Monetary Thresholds

Ballard Spahr LLP on

The Financial Crimes Enforcement Network (“FINCEN”) announced on November 15 that it has renewed and revised its Geographic Targeting Orders (“GTOs”) that require U.S. title insurance companies to identify the natural persons...more

Ballard Spahr LLP

FinCEN Issues Exceptive Relief from Beneficial Ownership Rule to Certain Account Renewals

Ballard Spahr LLP on

FinCEN Cites Low Risk of Money Laundering and High Regulatory Burden of Rule - On September 7, 2018, the Financial Crimes Enforcement Network (“FinCEN”) issued permanent exceptive relief (“Relief”) to the Beneficial...more

Foodman CPAs & Advisors

LAW ENFORCEMENT and OTHERS DISSAPOINTED with ULTIMATE BENEFICIAL OWNERSHIP DRAFT LEGISLATION

There is a Bill (H.R. 6068), originally drafted on November 14, 2017, called the Counter Terrorism and Illicit Finance Act (CTIFA). The Bill intended to propose a substantial overhaul to the Bank Secrecy Act (BSA). ...more

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