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BSA/AML U.S. Treasury FinCEN

Mayer Brown

FinCEN Finalizes Residential Real Estate Reporting Requirements

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On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) finalized a rule to require reporting of certain US residential real estate transactions (“Final Rule”). The Final Rule...more

Lowenstein Sandler LLP

The Real (Estate) Deal: FinCEN’s New Reporting Requirements for Property Transfers

In response to illicit finance risks identified in the U.S. residential real estate sector, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced the issuance of its long-anticipated...more

Freiberger Haber LLP

Enforcement News: SEC Charges Bank With Misleading Investors About The Strength Of Its BSA/AML Compliance Program And Its...

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The Currency and Foreign Transactions Reporting Act, also known as the “BSA,” enacted in 1970, established requirements for record-keeping and reporting by banks and other financial institutions. The BSA is designed to, among...more

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 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

White & Case LLP on

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

Lowenstein Sandler LLP

U.S. Treasury Renews Push to Make Investment Advisers Subject to the BSA

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The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more

Goodwin

FinCEN Issues Final Rule on Beneficial Ownership Information Access and Safeguards; Bank Regulators Issue Interagency Statement...

Goodwin on

On December 21, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (Access Rule) regarding access to the beneficial ownership information (BOI) reported to FinCEN...more

BakerHostetler

Treasury Revisits Past Rulemaking to Bring Investment Advisers Under AML Oversight

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In connection with the Biden Administration’s ongoing crackdown on corruption, tax havens, and illicit financing, on December 11, Treasury released a Fact Sheet on its “efforts to address the illicit finance and national...more

Perkins Coie

FFIEC BSA/AML Exam Manual Updates - Implications for Banks

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The Federal Financial Institutions Examination Council (FFIEC) released the fifth phase of updates to the FFIEC Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual (the Manual) on August 2, 2023. While the...more

Ballard Spahr LLP

“Tri-Seal” Compliance Notice: U.S. Authorities Release Joint Guidance on Voluntary Self-Disclosure of Potential Sanctions and...

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On July 26, the Department of Commerce, the Department of the Treasury, and the Department of Justice released a joint compliance notice (the “Compliance Notice”) updating and summarizing each agency’s position regarding the...more

Venable LLP

Treasury Doubles Up Enforcement Efforts Against Noncompliant Crypto Platforms

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​​​​​​​The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) announced yesterday that they had reached settlements for over $24 million and $29 million,...more

Sheppard Mullin Richter & Hampton LLP

Treasury’s Study Discusses Financial Crimes and NFTs

On February 4, the Department of the Treasury published a study on the facilitation of money laundering and terrorist financing through the art trade. Among other considerations, the report discussed the risks of financial...more

Goodwin

FinCEN Issues Report Addressing NFTs

Goodwin on

On February 4, 2022, the Treasury Department’s Financial Crimes Enforcement Network (FINCEN) jumped into the regulatory discussion about non-fungible tokens (“NFTs”) - more with a whisper than a bang - in a report on its...more

Eversheds Sutherland (US) LLP

Treasury study expresses concern about money laundering risks associated with NFTs 

On February 4, 2022, the US Department of the Treasury (the Treasury) released the “Study of the Facilitation of Money Laundering and Terror Finance through the Trade in Works of Art” (the Report). The Report examines the...more

BakerHostetler

$3.6 Billion Reasons to Up Cryptocurrency Compliance: FBI Cracking Down on Crypto Criminals

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Key Takeaways - ..Banks and cryptocurrency exchanges need to update their BSA programs to account for the unique aspects of cryptocurrencies, detect and report related suspicious activity, and minimize the risk of...more

King & Spalding

FinCEN Requests Comments on Beneficial Ownership Reporting Requirement; FinCEN’s Request For Information Moves U.S. Towards...

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The United States Department of the Treasury (“Treasury”) is taking further action to combat corruption, money laundering, terrorist financing, tax fraud, and other illicit activities. Following its Advance Notice of...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

Perkins Coie

AMLA 2020 Series Part 1: New and Expansive Beneficial Ownership Reporting Requirements

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As we reported in April, the Anti-Money Laundering Act of 2020 (AMLA 2020) aims to strengthen protections against money laundering, terrorism financing, and other illegal activities through a variety of mechanisms, including...more

McGlinchey Stafford

Do You Need To Know Your Customer?

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Auto dealerships and lenders are likely familiar with “know your customer” requirements, which typically involve obtaining identification information from customers and verifying that information. Most lenders are also...more

Morrison & Foerster LLP

Financial Services Report - Summer 2021

As spring turns to summer, climate change is on our minds. A new day, a new story about how financial institutions are addressing climate-related risks. In the past few months, six major banks—Bank of America, JPMorgan...more

Ballard Spahr LLP

PPP Lenders and Fraudulent Borrowers: False Claims Act Liability and AML Risk

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Can BSA/AML Requirements Lead to Deemed Knowledge of Borrower Fraud? The first two weeks of August brought a milestone of sorts in the ongoing recovery from the economic downturn brought on by the COVID-19 pandemic. The...more

Manatt, Phelps & Phillips, LLP

Federal Banking Agencies Issue BSA/AML Enforcement Guidance

On August 13, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration and the Office of the Comptroller of the Currency (collectively, the...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

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