News & Analysis as of

BSA/AML Financial Institutions Shell Corporations

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

Orrick - Finance 20/20

FinCEN Urges Financial Institutions to Focus on Detecting Proceeds of Foreign Public Corruption

Orrick - Finance 20/20 on

The Financial Crimes Enforcement Network (“FinCEN”) recently issued an advisory urging financial institutions (including certain cryptocurrency businesses) to implement controls to help detect proceeds of foreign public...more

Polsinelli

Corporate Transparency Act – Your Beneficial Entity Ownership Disclosure Is Now Required

Polsinelli on

Executive Summary - The U.S. Congress recently passed the Corporate Transparency Act (“CTA”) as part of the 2021 National Defense Authorization Act. The CTA requires certain corporations, limited liability companies and...more

Ballard Spahr LLP

Trade-Based Money Laundering: GAO Report Stresses Enforcement Challenges

Ballard Spahr LLP on

On January 29, 2020, the U.S. Government Accountability Office (GAO) publicly released the results of a study which the GAO conducted on trade-based money laundering, or TBML, entitled “Countering Illicit Finance and Trade:...more

Eversheds Sutherland (US) LLP

The OCC’s 2019 annual report addresses anti-money laundering risks for financial institutions

The Office of Comptroller of the Currency (the OCC) has published its 2019 annual report (the Annual Report), which summarized the OCC’s strategic priorities for 2019. The Annual Report also highlighted the OCC’s key...more

Cadwalader, Wickersham & Taft LLP

FinCEN Issues New Geographic Targeting Order for Shell Companies Purchasing High-End Residential Real Estate

In its latest effort to combat money laundering within the real estate sector, the Financial Crimes Enforcement Network (“FinCEN”) has issued a new Geographic Targeting Order (“GTO”) broadening its scrutiny of shell companies...more

Burr & Forman

Aloha Cash Buyers: FinCEN Issues Advisory to Financial Institutions; Expands Geographic Tracking Order to Include Honolulu, Wire...

Burr & Forman on

The Financial Crimes Enforcement Network (FinCEN) announced the revision of its Geographic Targeting Orders (GTO) Tuesday. The GTO requires title insurers to report beneficial ownership information on legal entities,...more

The Volkov Law Group

Corporate Shell Games and KYC Requirements

The Volkov Law Group on

Anti-money laundering professionals are in for a rude awakening. Know Your Customer or KYC requirements are currently kicking up a notch, and will be even more dramatic when the new FinCEN beneficial ownership regulations...more

The Volkov Law Group

AML Enforcement and Compliance Trends

The Volkov Law Group on

Law enforcement focus on anti-money laundering appears to be increasing. While the last ten years has seen a marked increase in AML regulatory obligations, the new administration is likely to return to some of the more...more

Robins Kaplan LLP

Your Daily Dose of Financial News

Robins Kaplan LLP on

FinCEN is extending its campaign to press title insurance companies to reveal the real buyers behind shell companies that pay cash for high-end real estate deals in select cities around the country....more

Ballard Spahr LLP

FinCEN Renewal of GTOs for High-End Cash Buyers in Six Markets

Ballard Spahr LLP on

FinCEN announced today that it is renewing the existing Geographical Targeting Orders (GTOs) issued in July 2016 that require all title insurance companies to identify and report on the natural persons behind shell companies...more

Foodman CPAs & Advisors

De-Risking 101

Foodman CPAs & Advisors on

Bank Secrecy Act of 1970 - Requires U.S. financial institutions to assist U.S. government agencies to detect and prevent money laundering by keeping records of cash purchases of negotiable instruments, and file reports...more

The Volkov Law Group

Customer Due Diligence in the Post-Panama Papers Era

The Volkov Law Group on

Sometimes it takes a scandal to advance a policy or law enforcement cause. The Panama Papers scandal has given new life to financial regulators around the world who seek to impose customer due diligence requirements on banks...more

Holland & Knight LLP

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

Holland & Knight LLP on

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

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