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Financial Crimes Suspicious Activity Reports (SARs)

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Ballard Spahr LLP

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

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On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate.  The Federal Register...more

K2 Integrity

Pending FinCEN Investment Adviser Rule: Industry Perspective On Next Steps You Should Be Taking

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On 22 August 2024, K2 Integrity hosted a webinar discussing considerations related to the pending anti-money laundering rule (AML) for investment advisers (IAs) from the Financial Crimes Enforcement Network (FinCEN). The...more

Ballard Spahr LLP

FinCEN Highlights Differences in CDD Rule and CTA Reporting of BOI

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The Financial Crimes Enforcement Network (“FinCEN”) has published a two-page reference guide (“Guide”) comparing the requirements for reporting beneficial ownership information (“BOI”) to FinCEN under the Corporate...more

Ballard Spahr LLP

BSA Filings and Their Utility to Law Enforcement:  An Industry Viewpoint

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In this post, we will once again consider the issue of the utility of Bank Secrecy Act (BSA) filings to the global anti-money laundering/countering the financing of terrorism (AML/CFT) compliance regime....more

Ballard Spahr LLP

Federal Banking Agencies Issue NPRM Consistent with FinCEN’s AML/CFT Modernization Proposal

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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

Troutman Pepper

Following FinCEN’s Lead, Four Federal Banking Regulators Announce AML/CFT Rulemaking

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As discussed here, on June 28, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed significant amendments to the anti-money laundering and countering the financing of terrorism...more

Ballard Spahr LLP

BSA Filings and Their Utility to Law Enforcement:  A Guest Blog

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Yesterday we were very pleased to welcome guest blogger, Don Fort, who is the Director of Investigations at Kostelanetz LLP, and the past Chief of the Internal Revenue Service’s Criminal Investigation (CI) Division....more

Ballard Spahr LLP

FinCEN Issues Proposed Rulemaking Aimed at Strengthening and Modernizing AML Programs Across Multiple Industries

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On July 3, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) as part of a broader initiative to “strengthen, modernize, and improve” financial institutions’ anti-money...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

Ballard Spahr LLP

FinCEN Issues Reminder to Financial Institutions to Identify and Report Elder Financial Exploitation

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On June 14, 2024, President Biden declared June 15th World Elder Abuse Awareness Day.  In honor of the day, the Financial Crimes Enforcement Network (FinCEN) reminded financial institutions (FIs) to remain vigilant in...more

Ballard Spahr LLP

FinCEN Releases Year-in-Review for FY 2023: SARs, CTRs and Information Sharing

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The Financial Crimes Enforcement Network (“FinCEN”) has issued its Year in Review for FY 2023 (“YIR”). It consists of five pages of infographics. According to FinCEN’s press release...more

Stinson LLP

SEC, FinCEN Propose Customer Identification Program Requirements for RIAs and ERAs

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On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking (proposed rule) that would impact how investment advisers handle...more

Troutman Pepper

Investment Management Update - Q1 2024

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This update covers legal developments and regulatory news for funds, their advisers, and industry participants for the quarter ended March 31. Rulemaking and Guidance: • SEC Adopts Reforms Relating to Investment Advisers...more

Ballard Spahr LLP

FinCEN Issues Analysis of Increasing Elder Financial Exploitation

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The Financial Crimes Enforcement Network (“FinCEN”) recently issued a Financial Trend Analysis (“Analysis”) focusing on patterns and trends identified in Bank Secrecy Act (“BSA”) data linked to Elder Financial Exploitation...more

Ballard Spahr LLP

FinCEN Issues Notice on Counterfeit Passport Card Fraud

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The Financial Crimes Enforcement Network (“FinCEN”) has issued a Notice on the Use of Counterfeit U.S. Passport Cards to Perpetrate Identity Theft and Fraud Schemes at Financial Institutions (“Notice”), asking financial...more

Thomas Fox - Compliance Evangelist

Using RegTech To Enhance the Fight Against Financial Crime

Have you heard these common myths about anti-money laundering technology solutions? Myth 1: Anti-money laundering technology solutions are only necessary for financial institutions. Myth 2: Anti-money laundering technology...more

Dorsey & Whitney LLP

FinCEN Proposes AML Compliance Obligations for Non-Financed Real Estate Transactions

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Following consideration of comments received from an Advanced Notice of Proposed Rulemaking, on February 16, 2024, FinCEN issued a proposed rule (the “Proposed Rule”) that for the first time would require non-financed...more

Woodruff Sawyer

Only You (Investment Advisers)! Can Prevent Money Laundering

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If you are an investment manager and you significantly and repeatedly outperform the market, your investors will lavish you with righteous praise and your firm will shower you with well-deserved riches....more

Bilzin Sumberg

U.S. Transparency Updates

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The United States has started with a bang for 2024 with respect to transparency initiatives. The initiatives affect real estate, financial and business sectors. This alert provides a brief overview of the developments in...more

Foodman CPAs & Advisors

ALD/FT Viene A Los “Investment Advisers”

El 15 de febrero de 2024, FinCEN publicó un Aviso de Reglamentación Propuesta (NPRM) que requeriría que ciertos asesores de inversiones (Investment Advisers) apliquen requisitos de ALD/FT conforme con la Ley de Secreto...more

Foodman CPAs & Advisors

AML/CFT Coming To Investment Advisers

On 2/15/24, FinCEN published a Notice of Proposed Rulemaking (NPRM) that would require certain investment advisers to apply AML/CFT requirements pursuant to the Bank Secrecy Act, including implementing risk-based AML/CFT...more

Foodman CPAs & Advisors

Reporte Real Estate De FinCEN

El 7 de febrero de 2024, FinCEN emitió un Aviso de Reglamentación Propuesta (NPRM) para combatir y disuadir el lavado de dinero en el sector inmobiliario residencial de EE. UU. mediante el aumento de la transparencia. FinCEN...more

Foodman CPAs & Advisors

Real Estate Report From FinCEN

On February 07, 2024, FinCEN issued a Notice of Proposed Rulemaking (NPRM) to combat and deter money laundering in the U.S. residential real estate sector by increasing transparency. FinCEN is seeking to require certain...more

Cadwalader, Wickersham & Taft LLP

FinCEN’s Proposed Rulemaking: Enhancing Transparency in Residential Real Estate

While many Americans are struggling to achieve the dream of homeownership, there are criminals that abuse the housing market for financial gain. To avoid the scrutiny of financial institutions that have anti-money laundering...more

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