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Financial Services Industry Recordkeeping Requirements FinCEN

White & Case LLP

The Shadow Financial System

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The concept of the shadow financial system rose to international prominence in the aftermath of the 9/11 terrorist attacks. In an interview with a Pakistani newspaper a month later, Osama bin Laden stated that Al Qaeda were...more

Dechert LLP

SEC, FinCEN Propose CIP Rules for Investment Advisers

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The Proposed Rule would require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish, document and maintain written customer identification programs (CIPs). The Proposed Rule comes...more

Mayer Brown Free Writings + Perspectives

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...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

Ballard Spahr LLP

FinCEN Proposes to Require Recordkeeping and Reporting for CVC Mixing Transactions

Ballard Spahr LLP on

On October 23, the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“NPRM”) entitled Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of...more

Goodwin

Agencies Launch Digital Identity Tech Sprint

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In This Issue. The Federal Deposit Insurance Corporation (FDIC), the FDIC Tech Lab (FDITECH) and the Financial Crimes Enforcement Network (FinCEN) launched a digital identity Tech Sprint; FinCEN published a 60-day notice to...more

Kramer Levin Naftalis & Frankel LLP

FinCEN Considers New Anti-Money Laundering Reporting Requirements For All-Cash Real Estate Transactions

The Financial Crimes Enforcement Network (FinCEN) of the Treasury Department announced last week an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on a proposed rule that would address the...more

Goodwin

FinCEN Issues Proposed Rule for Beneficial Ownership Information Reporting Requirements

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) announced (1) a notice of proposed rulemaking for beneficial ownership information reporting requirements and (2) a regulatory process for new real estate...more

Foodman CPAs & Advisors

Will Financial Institutions be Ready for the Proposed Travel Rule Rulemaking?

The “Travel Rule” is a Bank Secrecy Act (BSA) rule [31 CFR 103.33(g)] that requires financial institutions to pass certain information on to the next financial institution, in certain funds transmittals involving more than...more

Goodwin

SEC Finalizes Reforms Under Investment Advisers Act

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In this Issue. The Securities and Exchange Commission (SEC) finalized reforms under the Investment Advisers Act to modernize rules that govern investment adviser advertisements and payments to solicitors, and published a risk...more

K2 Integrity

Proposal to Revise Recordkeeping and Travel Rule Requirements Poses Implementation Challenges for FIs and VASPs

K2 Integrity on

The U.S. Financial Crimes Enforcement Network (FinCEN) and the Board of Governors of the U.S. Federal Reserve System (FRB) proposed new rules that would expand the applicability of recordkeeping and travel rule requirements,...more

Goodwin

OCC Finalizes “True Lender” Rule

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In the News. The Office of the Comptroller of the Currency (OCC) finalized its “true lender” rule, which establishes that a national bank or federal savings association (bank) is the “true lender” of a loan if, as of the...more

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