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FinCEN › Bank Secrecy Act › Compliance

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
Foodman CPAs & Advisors

NTA Addresses Overlap Reporting

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On 1/8/25, the National Taxpayer Advocate (NTA) published its 2024 Annual Report to Congress and identified taxpayers’ problems and provided suggestions to further protect taxpayer rights and ease taxpayer burden. “By law,...more

K2 Integrity

Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now?

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On 15 January 2025, K2 Integrity hosted a webinar that featured Justina Rousseau, senior managing director at K2 Integrity; Aseel Rabie, counsel at Debevoise & Plimpton LLP; and Sarah Runge, executive managing director at K2...more

K2 Integrity

Fiat Ramps Unlocked: Practical Tips For Banks And Crypto Firms

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Ask any centralized cryptocurrency firm to name one of their biggest priorities or challenges—and then count the number of times they mention bank partnerships. For crypto firms, the loss of, or failure to acquire, a bank...more

Paul Hastings LLP

State-Level Developments: The Regulatory Landscape for Digital Assets

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As we begin the 119th Congress, the nation is also preparing for the new administration to take office in just a few weeks. While federal action on digital assets remains a key focus, this week’s Crypto Policy Tracker shifts...more

Freiberger Haber LLP

Enforcement News: Broker-Dealers Settle Charges for Filing Deficient SARs

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The Bank Secrecy Act (“BSA”) and implementing regulations promulgated by the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) require that broker-dealers file a suspicious activity report (SAR”) with...more

Foodman CPAs & Advisors

TD Bank gets $1.3 Billion Penalty from FinCEN

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On 10/10/24, FinCEN assessed a record $1.3 billion penalty against TD Bank for BSA violations. This unprecedented penalty should function as a cautionary message and a warning to all financial institutions. All financial...more

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

Thomas Fox - Compliance Evangelist

TD Bank: Part 5- The Reckoning

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Today, I want to review the OCC Consent Order to see the bank’s requirements. This is separate from the DOJ requirements under the Bank’s Plea Agreement(s) and the FinCEN Consent. Further, the DOJ and OCC have mandated...more

Bradley Arant Boult Cummings LLP

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

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On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

The Volkov Law Group

TD Bank’s $3 Billion Settlement: A Review of Regulatory Settlements  (Part III of IV)

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TD Bank’s $3 billion settlement included coordinated regulatory settlements with the Federal Reserve Board (“Federal Reserve”), The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), and the...more

Neal, Gerber & Eisenberg LLP

New FinCEN Rule Imposes AML Requirements on Investment Advisers

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that will define most SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) as...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 2 – When Profits Trump Compliance: A Recipe for Corporate Disaster

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We continue our exploration of the resolution of the AML/BSA enforcement action involving TD Bank US (the Bank), which is wholly owned by TD Bank Group, a publicly traded (NYSE: TD) international banking and financial...more

The Volkov Law Group

TD Bank Agrees to Pay Over $3 Billion for Systemic Violations of Bank Secrecy Act and Money Laundering Violations (Part I of IV)

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In yet another reminder of the scope of Justice Department enforcement powers, and an important demonstration of the risks of non-compliance, the Justice Department and relevant banking agencies announced a $3 billion...more

Thomas Fox - Compliance Evangelist

TD Bank: Part 1-Money Laundering and the China Syndrome

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Last week, representatives of the US government announced one of the largest sets of fines and penalties for failures in anti-money laundering ever laid down. It involved TD Bank N.A. and TD Bank US Holding Company. It was...more

Goodwin

FinCEN Adopts Final AML Program Rule for Investment Advisers

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...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

Goodwin

FinCEN Adopts Reporting Requirement for Non-Financed Residential Real Estate Transfers

Goodwin on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a final rule (the Residential Real Estate Rule) requiring certain persons involved in residential real estate closings and...more

King & Spalding

FinCEN Issues Final Rule Expanding Anti-Money Laundering/ Countering the Financing of Terrorism Requirements for Investment...

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On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more

Alston & Bird

Investment Advisers Face New AML/CFT Compliance Obligations from FinCEN

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Our Financial Services, Investment Funds, and White Collar, Government & Internal Investigations Teams break down the latest Financial Crimes Enforcement Network (FinCEN) rule investment advisers must prepare for....more

Holland & Knight LLP

FinCEN Issues Final Rule on AML/CFT Requirements for Investment Adviser Sector

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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

DLA Piper

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

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Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more

Perkins Coie

What Is an “Effective AML/CFT Compliance Program”?

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The Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies recently published the long-awaited notice of proposed rulemaking for the anti-money laundering/countering the financing of terrorism...more

Holland & Hart LLP

Key Compliance Takeaways for Companies from the DOJ's New Corporate Whistleblower Program

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On August 1, 2024, the U.S. Department of Justice (“DOJ”) announced its new “Corporate Whistleblower Awards Pilot Program” (“DOJ Program”), a three-year initiative managed by DOJ’s Money Laundering and Asset Recovery Section....more

Latham & Watkins LLP

Agencies Issue Joint Proposal to Amend Bank Secrecy Act Compliance Programs for Banks

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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

Guidepost Solutions LLC

Can a Failed Privacy Program Lead to Fentanyl Trafficking or OFAC Violations?

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In July 2024, the Federal Bureau of Investigation and Department of Treasury’s Financial Crime Enforcement Network and Office of Foreign Assets Control (OFAC) released a joint notice discussing how Mexican-based Transnational...more

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