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Customer Due Diligence (CDD) Compliance FinCEN

Holland & Knight LLP

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Aug. 28, 2024, issued a final rule to help safeguard the investment adviser sector from illicit finance activity (Final Rule). The Final...more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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On July 19, 2024, the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration...more

Holland & Knight LLP

FinCEN Reference Guide Clarifies Beneficial Ownership Reporting Requirements

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on July 26, 2024, issued a notice containing a reference guide for customers of financial institutions (the Reference Guide). The Reference...more

Royer Cooper Cohen Braunfeld LLC

SEC & FinCEN Propose Customer Identification Program Requirements

A press release was recently issued describing a significant joint proposal by the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The proposal...more

Seward & Kissel LLP

FinCEN Proposes AML Requirements for Certain Investment Advisers

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On February 13, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (the “Proposed Rule”) that would subject registered investment advisers (“RIAs”) and...more

King & Spalding

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

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The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

Holland & Knight LLP

FinCEN Issues Final Rule Implementing Access and Safeguard Provisions of the CTA

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The Corporate Transparency Act (CTA) was enacted in 2021 and became effective on Jan. 1, 2024. The CTA was passed with the aim of enhancing transparency in corporate ownership, so as to combat the proliferation of anonymous...more

Dorsey & Whitney LLP

FinCEN’s Final Regulations to Implement the Corporate Transparency Act

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Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

Stark & Stark

The Corporate Transparency Act and Reporting Requirements

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On January 1, 2024, the Corporate Transparency Act, 33 U.S.C. §5336, (the “CTA”) took effect and strict compliance must be met by all entities and individuals to which it applies. The CTA adds reporting requirements for...more

Dorsey & Whitney LLP

FinCEN Issues Final Regulations to Implement the BSA’s Revised Beneficial Ownership Requirements

Dorsey & Whitney LLP on

Pursuant to the adoption of comprehensive revisions to the U.S. anti-money laundering statutes as part of the Defense Appropriations Act of 2021 (the “Defense Act”), on September 30, 2022, the Financial Crimes Enforcement...more

King & Spalding

The Anti-Money Laundering Act and Crypto Collide: Non-Fungible Tokens

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As NFTs gain popularity, buyers and sellers should consider the potential issues related to federal anti-money laundering laws. While non-fungible tokens (“NFTs”) have existed for several years, the market for NFTs grew...more

The Volkov Law Group

The Coming AML Enforcement Storm

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Blog after blog, commentator after commentator, and everyone else who has an opinion has been repeating the same message – the Biden Administration is going to increase enforcement risks....more

NAVEX

Clarifying New Customer Due Diligence (CDD) Guidance on PEPs

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Compliance officers in financial services have long struggled with aspects of Customer Due Diligence, better known as the CDD Rule. This fall, compliance professionals are scratching their heads to know exactly how much due...more

Holland & Knight LLP

Treasury Releases 2020 National Strategy for Combating Terrorist and Other Illicit Financing

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The 2020 National Strategy for Combating Terrorist and Other Illicit Financing was issued earlier this month by the U.S. Department of the Treasury. Prepared in consultation with regulators and law enforcement, including the...more

White & Case LLP

Review of Anti-Money Laundering and Sanctions Policy and Enforcement

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TABLE OF CONTENTS: Executive Summary - Developments and Trends in Policy and Enforcement - US Department of the Treasury - The Office of Foreign Assets Control - Treasury's Financial Crimes Enforcement Network -...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tackling the Challenges of Complying With FinCEN’s New Customer Due Diligence Rule

Effective May 11, 2018, covered financial institutions are required to comply with the customer due diligence rule (the Rule) that the Financial Crimes Enforcement Network (FinCEN) finalized in May 2016. The Rule mandates the...more

The Volkov Law Group

FinCEN Issues Guidance for Beneficial Ownership Regulations

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Financial institutions face an important deadline – May 11, 2018 is the effective date for the new customer due diligence regulations governing beneficial ownership requirements. FinCEN provided financial institutions nearly...more

Dechert LLP

FinCEN Issues FAQs for Customer Due Diligence Rule; Compliance Required in May

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The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) on April 3, 2018 issued Frequently Asked Questions Regarding Customer Due Diligence Requirements for Financial Institutions (FAQs). The FAQs address various...more

Harris Beach PLLC

Customer Due Diligence Deadline Nears

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Financial institutions face a pending deadline to meet new customer due diligence requirements. FinCEN has issued updated Frequently Asked Questions to assist financial institutions in understanding the scope of the...more

The Volkov Law Group

AML Regulation and Compliance Trends

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Regulators and enforcement agencies continue to pursue aggressive regulations and requirements for financial institutions (a very broad definition under Title 31 of the US Code and regulations). The new administration does...more

The Volkov Law Group

May 2018: D-Day for FinCEN Customer Due Diligence and EU’s General Data Privacy Regulations

The Volkov Law Group on

Chief compliance officers for financial institutions are going to have a rough May 2018. First, on May 11, 2018, the new CDD Rule for beneficial ownership becomes effective. Two weeks later, on May 25, 2018, the EU’s...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Expands Scope of “All Cash” GTOs

Continuing its efforts to deter the use of real estate as a vehicle to launder proceeds of criminal activity, the Financial Crimes Enforcement Network (FinCEN) recently announced its plan to extend the reach and time frame of...more

The Volkov Law Group

Addressing AML Risks in the Era of Aggressive Enforcement

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The resurgence in anti-money laundering enforcement in the last few years reflects the overall improvement in the banking industry and recovery from the financial collapse. Federal prosecutors and regulators have renewed...more

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