How Will the Anti-Money Laundering Act of 2020 and the Corporate Transparency Act Impact Banks’ Anti-Money Laundering Compliance Under the Bank Secrecy Act? A Discussion with Guest Matt Haslinger
Compliance Perspectives: Due Diligence and Ultimate Beneficial Ownership (UBO)
Earlier this summer, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Proposed Rule revising its regulations under the Bank Secrecy Act (BSA) requiring financial institutions to...more
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
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
Last week, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a joint statement highlighting...more
The federal banking agencies, including 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...more
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
The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more
In February 2024, the Federal Deposit Insurance Corporation (FDIC) entered into consent orders with two banks who partner with fintechs to offer “banking as a service” (BaaS) related to safety and soundness, compliance with...more
On February 13, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule that would require federal investment advisers to add Bank Secrecy Act (“BSA”) type anti-money...more
On February 1/3, the Financial Crimes Enforcement Network (FinCEN) proposed a new rule (the Proposed Rule), that, if adopted, would add certain investment advisers to the definition of “financial institution” under the Bank...more
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
On December 21, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Financial Crimes Enforcement Network (FinCen), the National Credit Union Administration, along with...more
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued its highly anticipated final rule implementing the beneficial ownership information (BOI) reporting requirements of the Corporate...more
As we have repeatedly blogged, concerns about perceived anti-money laundering (“AML”) risks in the real estate industry are rising globally. Consistent with this concern, the Financial Action Task Force (“FATF”) has updated...more
The Financial Action Task Force (FATF) recently published a report titled Virtual Assets: Red Flag Indicators of Money Laundering and Terrorist Financing. The report discusses a number of red flag indicators of suspicious...more
Six steps can take institutions beyond merely good. What makes for a great anti-money laundering compliance program? This is not a pie-in-the-sky idea. As financial institutions strive to keep up with evolving regulations...more
On March 31st the Financial Action Task Force (FATF)—the global AML/CFT standard-setting body and watchdog—announced that it has upgraded the United States for technical compliance with FATF Recommendation 10 following...more
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
Growing Chinese illicit finance threats, vulnerabilities, and exposure are combining to increase illicit financing risk in the international financial system, judging from a series of recent advisories, sanctions actions,...more
The Financial Action Task Force is seeking feedback from private sector stakeholders on its draft guidance on the use of digital identity systems in customer due diligence. The guidance will supplement Recommendation 10 of...more
The FATF (FATF) is an inter-governmental body with 38 members that sets standards and promotes the implementation of legal, regulatory and operational measures for combating money laundering, terrorist financing and threats...more
Fulfilling today’s requirements for anti-money laundering and counterterrorism financing/sanctions compliance is no easy task for financial institutions. ...more
The Joint Committee of European Supervisory Authorities has published an Opinion addressed to EU national regulators to develop a common understanding of the appropriate use, by credit and financial institutions, of...more
There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities. The U.S. Government is determined to enforce financial...more
Because they are known as “gatekeepers” in the financial industry, Professional Service Providers (PSPs), Bankers, Brokers, Realtors, Casino Managers, Trust Fund Managers, Money Managers, etc., carry a level of responsibility...more