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Financial Institutions Anti-Money Laundering Policies and Procedures

ArentFox Schiff

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

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On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Perkins Coie

FDIC’s Proposed Changes to Custodial Deposit Accounts: Practical Implications for Fintechs and Their Banks

Perkins Coie on

The Federal Deposit Insurance Corporation (FDIC) issued a Notice of Proposed Rulemaking (the Proposal) on September 17, 2024, that seeks to strengthen recordkeeping for bank deposits held by nonbank companies on behalf of...more

Goodwin

FinCEN and Banking Agencies Propose AML Program Rule Updates for Banks and Other Financial Institutions

Goodwin on

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

Conyers

Regulatory & Risk Advisory Review: Cayman Islands - April to June 2024

Conyers on

Welcome to the second instalment of 2024 of the Regulatory & Risk Advisory Review. In this edition we cover several Cayman Islands regulatory updates including updates to the Beneficial Ownership Transparency Act, the...more

Skadden, Arps, Slate, Meagher & Flom LLP

FinCEN Seeks To Expand Reach of the BSA and Modernize Customer Identification Regulations

The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has recently taken steps to expand the reach of the Bank Secrecy Act (BSA) and related customer identification regulations. These steps build on...more

Eversheds Sutherland (US) LLP

FinCEN and SEC propose Customer Identification Program requirements for investment advisers

Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

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

Seward & Kissel LLP

FinCEN Proposes New Rule to Subject Advisers to AML Requirements

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Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Proposes New Rule to Expand Anti-Money Laundering Requirements for Investment Advisers

Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more

Walkers

Director exemptions: changes to AML obligations

Walkers on

Introduction - Further to a recent update, in which the Government, in consultation with the Jersey Financial Services Commission ("JFSC"), announced its intention to make legislative changes to the anti-money laundering,...more

White & Case LLP

Amendment to the Anti-Money Laundering Regulations applicable to Investment Advisors and Credit Unions, for the remote onboarding...

White & Case LLP on

On January 20, 2023, the Ministry of Finance and Public Credit issued resolutions that amend the Anti-Money Laundering ("AML") General Provisions (the "Amendments") applicable to Investment Advisors, and Credit Unions,...more

Oberheiden P.C.

5 Anti-Money Laundering Compliance and Defense Tips

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1. AML Laws - Federal anti-money laundering (“AML”) laws are complex in nature and apply to a broad category of institutions and businesses. One of the most important AML laws is the Bank Secrecy Act, which obligates...more

Katten Muchin Rosenman LLP

Businesses Must Prepare For Expansive AML Reporting of Beneficial Ownership Interests

As covered in our earlier advisory, "AML Enforcement Continues to Trend in 2021," the recently passed National Defense Authorization Act for fiscal year 2021 included the Anti-Money Laundering Act of 2020 (AML Act), which...more

Foodman CPAs & Advisors

The BSA Casts A Wider Net

On  September 15, 2020,  FinCEN issued a Final Rule stating that Banks lacking a Federal Functional Regulator will be required to establish and implement AML programs including policies and procedures,  a dedicated compliance...more

Foodman CPAs & Advisors

Who are you partnering with for your Financial Institution’s BSA/AML Independent Testing?

Financial Institutions ought to design and evaluate compliance programs to meet BSA/AML requirements and to satisfy Bank Examiner expectations. A Financial Institution’s Compliance Programs must comply with the requirements...more

Stinson LLP

Missouri Financial Institutions Must Prepare for Impending Marijuana Banking Challenges

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In November 2018, Missouri voters passed Amendment 2, setting in motion state regulated medical marijuana. Over the last month, the Missouri Department of Health & Senior Services (DHSS) began approving license applications...more

Foodman CPAs & Advisors

Instituciones Financieras y el FCPA

La Ley de Prácticas Corruptas en el Extranjero (“Foreign Corrupt Practices Act – FCPA”) prohíbe el pago de sobornos a funcionarios extranjeros para ayudar a obtener o retener negocios.  Exige que las empresas cuyos valores se...more

Foodman CPAs & Advisors

Financial Institutions and the FCPA

The Foreign Corrupt Practices Act (FCPA) prohibits payment of bribes to foreign officials to assist with obtaining or retaining business.  It requires companies whose securities are listed in the US to maintain books and...more

Orrick, Herrington & Sutcliffe LLP

Antiriciclaggio: Banca d'Italia emana le nuove disposizioni su organizzazione, procedure e controlli interni

Banca d'Italia, con il Provvedimento del 26 marzo 2019, ha emanato le nuove "Disposizioni in materia di organizzazione, procedure e controlli interni volti a prevenire l'utilizzo degli intermediari a fini di riciclaggio e di...more

Ballard Spahr LLP

Practical Tips for Ensuring Your AML Program Withstands the Scrutiny of Regulators

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First Post in a Two-Part Series - How do financial institutions get in trouble with their regulators? Recent AML enforcement actions suggest that the following two failures are at the heart of most of these actions: (1)...more

Sullivan & Worcester

FFIEC Examination Procedures for the Beneficial Ownership Rule

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The FFIEC has updated its BSA/AML manual effective May 5, 2018, to add a section on the new legal entity due diligence requirements and to update the section of the manual on customer due diligence generally. The Fed...more

Pillsbury Winthrop Shaw Pittman LLP

Beyond BSA Compliance: Human Trafficking Corporate Liability for Small Banks and MSBs

Smaller banks and money services businesses should expand their AML compliance to mitigate human trafficking corporate liability. Aside from the Bank Secrecy Act, federal law creates corporate liability for financial...more

Dechert LLP

Financial Services Quarterly Report - Fourth Quarter 2017: Developments in the Luxembourg Financial Sector

Dechert LLP on

Luxembourg recently published two important bills to combat money laundering and terrorism financing – one transposes the EU AML4 Directive1 into Luxembourg law; the second establishes a central register of beneficial owners,...more

Bass, Berry & Sims PLC

Anti-Money Laundering Update: FinCEN Makes Small Texas Bank Pay Big Fine for Violating Bank Secrecy Act

Bass, Berry & Sims PLC on

This Post at a Glance: - FinCEN imposes $2 million penalty against community bank - Bank failed to conduct appropriate due diligence related to Mexican customer - Small banks, other financial institutions need to...more

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