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Financial Institutions › Reporting Requirements › Policies and Procedures

Guidepost Solutions LLC

Will your Due Diligence Program Meet the New DFS Requirement?

Guidepost Solutions LLC on

The final guidance, issued by DFS on January 22, 2024, requires “regular and rigorous” vetting of key personnel at banking organizations and non-depository institutions. It is clear, that DFS is focused on enhanced scrutiny...more

Bracewell LLP

Beneficial Ownership Information Reporting Under the Corporate Transparency Act

Bracewell LLP on

On January 1, 2024, the reporting requirements under the Corporate Transparency Act (CTA) became effective. The CTA was enacted by Congress on January 1, 2021, as part of the Anti-Money Laundering Act of 2020 and requires...more

Eversheds Sutherland (US) LLP

Key highlights of FinCEN’s final rule on access to Beneficial Ownership Information

Eversheds Sutherland (US) LLP on

The Financial Crimes Enforcement Network (FinCEN) issued the Beneficial Ownership Information Access and Safeguards Rule (Access Rule) establishing the framework for access to and protection of beneficial ownership...more

Holland & Knight LLP

Agency Guidelines Confirm That Climate-Related Financial Risk Is Real

Holland & Knight LLP on

The U.S. Department of the Treasury's Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board) and the Federal Deposit Insurance Corp. (FDIC) (collectively, the Agencies) on...more

Oberheiden P.C.

5 Anti-Money Laundering Compliance and Defense Tips

Oberheiden P.C. on

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

Stinson LLP

Missouri Financial Institutions Must Prepare for Impending Marijuana Banking Challenges

Stinson LLP on

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

Sullivan & Worcester

FFIEC Examination Procedures for the Beneficial Ownership Rule

Sullivan & Worcester on

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

K2 Integrity

Five Areas of Focus for the New CDD Rule

K2 Integrity on

While regulators haven’t yet spelled how the new customer due diligence (CDD) requirements for financial institutions will be implemented, banks, credit unions, securities firms, money services businesses, and casinos should...more

Ballard Spahr LLP

Agencies announce submission of diversity self-assessments to OMWIs can begin

Ballard Spahr LLP on

In a notice to be published in tomorrow’s Federal Register, the CFPB, OCC, Fed, FDIC, SEC, and NCUA announce that the Office of Management and Budget has approved the “information collection” contained in their “Final...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

Morrison & Foerster LLP on

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report...more

Foley Hoag LLP

FinCEN Proposed AML Rule For Investment Advisers

Foley Hoag LLP on

The Financial Crimes Enforcement Network (“FinCEN”), a bureau of the Department of Treasury, issued a proposed anti-money laundering rule applicable to investment advisers registered with the U.S. Securities and Exchange...more

Proskauer - Corporate Defense and Disputes

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

Proskauer - Corporate Defense and Disputes on

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

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