News & Analysis as of

FinCEN Customer Due Diligence (CDD) Due Diligence

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 -
Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

Holland & Knight LLP on

The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

NAVEX

Clarifying New Customer Due Diligence (CDD) Guidance on PEPs

NAVEX on

Compliance officers in financial services have long struggled with aspects of Customer Due Diligence, better known as the CDD Rule. This fall, compliance professionals are scratching their heads to know exactly how much due...more

Sheppard Mullin Richter & Hampton LLP

Clearing the Air: FinCEN Guidance May Help Banks Find Their Way in the Field of Hemp Financing

On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) published updated guidance intended to “enhance the availability of financial services” for the hemp industry (the Guidance). Even though the Agriculture...more

Foley & Lardner LLP

FinCEN Issues Updated Guidance for Due Diligence of Hemp Businesses

Foley & Lardner LLP on

The Financial Crimes Enforcement Network (“FinCEN”) recently released guidance for bank and financial institutions regarding the requirements and obligations for financial institutions under the Bank Secrecy Act (BSA) and...more

King & Spalding

FinCEN Finalizes Customer Due Diligence Requirements for Financial Institutions

King & Spalding on

On May 11, 2018, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) implemented its Final Rule on Customer Due Diligence Requirements for Financial Institutions (“Rule”) to amend the scope of...more

Morrison & Foerster LLP

Customer Due Diligence and Beneficial Ownership: Updates to FFIEC Examination Manual and FinCEN Administrative Ruling

May 11, 2018 was the applicability date for FinCEN’s new “Customer Due Diligence Requirements for Financial Institutions” (the “CDD Rule”). FinCEN noted the occasion by issuing a press release to remind covered financial...more

Kelley Drye & Warren LLP

Deadline Approaches for Implementation of FinCEN Customer Due Diligence Requirements

On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules which codify customer due diligence requirements for financial institutions (the “CDD Rule”)[1] under the Bank Secrecy Act (the “BSA”). ...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Enforcement Action Highlights AML Compliance Program Failures and Conflicts of Interest for High-Risk MSB Customers

On February 27, 2017, FinCEN announced a $7 million civil monetary penalty against Merchants for willful violations of the BSA. Additionally, the Office of the Comptroller of the Currency (OCC), Merchants’ federal functional...more

K&L Gates LLP

International AML Enforcement in 2017 Expected to Target Consumer-Due-Diligence Programs, Gaming Entities, Prepaid Cards, Digital...

K&L Gates LLP on

Over the past two years, financial regulatory bodies in the United States and Europe have increasingly emphasized consumer due diligence (“CDD”) by financial institutions as a means to combat money laundering and terrorist...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN Expands Scope of “All Cash” GTOs

Continuing its efforts to deter the use of real estate as a vehicle to launder proceeds of criminal activity, the Financial Crimes Enforcement Network (FinCEN) recently announced its plan to extend the reach and time frame of...more

Foodman CPAs & Advisors

Should Professional Service Providers Assume Greater AML Vigilance Responsibilities?

Because they are known as “gatekeepers” in the financial industry, Professional Service Providers (PSPs), Bankers, Brokers, Realtors, Casino Managers, Trust Fund Managers, Money Managers, etc., carry a level of responsibility...more

Pillsbury Winthrop Shaw Pittman LLP

A New Age of Transparency: U.S. Announces

On May 11, 2016, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury, published its final rule addressing Customer Due Diligence Requirements for Financial Institutions (CDD Rule)....more

Skadden, Arps, Slate, Meagher & Flom LLP

"FinCEN Finalizes Customer Due Diligence Rule Amid Other Actions to Enhance Financial Transparency"

In the wake of the Panama Papers controversy, the U.S. government has taken major steps this month to promote financial transparency. First, the Financial Crimes Enforcement Network (FinCEN) finalized its proposed rule issued...more

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