News & Analysis as of October 19, 2024

FinCEN › Final Rules

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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 -

FinCEN Issues Final Rule: Implications for Real Estate Money Laundering

Kohn, Kohn & Colapinto LLP on 10/18/2024

The Financial Crimes Enforcement Network (FinCEN), a bureau within the United States Department of Treasury, has issued a new investment advisor rule to protect residential real estate from illicit finance, such as money...more

What To Know About FinCEN's Investment Adviser AML Program Final Rule

Davis Wright Tremaine LLP on 10/8/2024

After two decades and three proposed rulemakings on whether investment advisers should have anti-money laundering (AML) and countering the financing of terrorism (CFT) program requirements and attempting to identify the...more

Jeopardy Question: Rates and Leaves -- Answer: What Are Things That Are Dropping?

Cadwalader, Wickersham & Taft LLP on 10/2/2024

FinCEN Issues Final Rule Designed to Combat Money-Laundering in Residential Real Estate Transactions: Money It’s a Gas, Grab That Cash With Both Hands and Make a Stash....more

FinCEN Issues Final Rule Designed to Combat Money-Laundering in Residential Real Estate Transactions: Money It’s a Gas, Grab That...

Cadwalader, Wickersham & Taft LLP on 10/1/2024

As part of an effort to combat money laundering in United States residential real estate transactions, the Financial Crimes Enforcement Network bureau of the United States Department of the Treasury (“FinCEN”) issued a final...more

FinCEN Issues Final Regulation Requiring the Reporting of Certain Non-Financed, Residential Real Estate Transfers

Cozen O'Connor on 10/1/2024

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a final rule requiring real estate professionals involved in real estate closings and settlements to...more

Treasury Department Releases Semiannual Regulatory Agenda

Troutman Pepper on 9/27/2024

On August 16, the U.S. Department of the Treasury published its semiannual regulatory agenda in the Federal Register, detailing the agency’s upcoming regulatory actions and priorities. The agenda outlines the proposed, final,...more

FinCEN Adopts AML/CFT Rules for Investment Advisers with Few Changes from Proposed Rules

BCLP on 9/23/2024

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more

Investment Advisers Subject to AML and SARs Requirements

Jones Day on 9/23/2024

The Situation: The Financial Crimes Enforcement Network ("FinCEN") has adopted a rule that subjects certain investment advisers to anti-money laundering/countering the financing of terrorism program ("AML") requirements...more

FinCEN Adopts Final AML Program Rule for Investment Advisers

Goodwin on 9/19/2024

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

FinCEN Issues Final Sweeping AML Requirements for Registered Investment Advisers & ERAs

White & Case LLP on 9/17/2024

On August 28, 2024, FinCEN issued a long-awaited final rule meant to address illicit finance activities and national security threats in the asset management industry. The new rule imposes similar requirements on investment...more

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

Ballard Spahr LLP on 9/13/2024

Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Department of the Treasury Releases New AML/CFT Rule for Investment Advisers

Seward & Kissel LLP on 9/13/2024

Who may be interested: Investment Advisers - Quick Take: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule subjecting certain registered investment advisers (RIAs) and...more

Financial Markets and Funds Quick Take | Issue 30

Katten Muchin Rosenman LLP on 9/12/2024

Katten's Financial Markets and Funds Quick Take is a monthly newsletter highlighting key noteworthy developments potentially affecting financial markets and funds....more

A New Federal Reporting Requirement Has Been Established for Non-Financed Transfers of U.S. Residential Real Estate to a Trust or...

Tucker Arensberg, P.C. on 9/12/2024

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued its “Anti-Money Laundering Regulations for Residential Real Estate Transfers” (the “Final Rule”), to become effective December 1, 2025. This Final...more

FinCEN’s Final Rule on Anti-Money Laundering for Residential Real Estate Transfers

King & Spalding on 9/12/2024

On August 29, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule under the Bank Secrecy Act (“BSA”) requiring certain persons involved in real estate closings and settlements to report and maintain...more

FinCEN Issues Final BSA Reporting Requirements for Residential Real Estate Deals

Ballard Spahr LLP on 9/11/2024

On August 29, the Financial Crimes Enforcement Center (“FinCEN”) published Anti-Money Laundering Regulations for Residential Real Estate Transfers (“Final Rule”) regarding residential real estate. The Federal Register...more

Treasury Issues Final Investment Advisers AML/CFT Program Rule

Dechert LLP on 9/11/2024

Treasury issued a final rule requiring certain investment advisers to establish an AML/CFT Program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Final Rule). The Final Rule applies to...more

Q&A on FinCEN’s New AML Requirements for Certain Investment Advisers

Seward & Kissel LLP on 9/11/2024

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

Foley Hoag LLP on 9/10/2024

On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

FinCEN adopts investment adviser AML rules

Eversheds Sutherland (US) LLP on 9/10/2024

The Financial Crimes Enforcement Network (FinCEN) adopted a final rule that adds most federal Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to the definition of “financial institution” under the...more

Looming Reporting Deadline Under the Corporate Transparency Act: The Reality Sets In

Venable LLP on 9/10/2024

Over three years ago, Congress enacted the federal Corporate Transparency Act ("CTA"), which for the first time obligates business owners, among others, to file beneficial ownership information ("BOI") reports with the U.S....more

FinCEN Finalizes Rule to Compel Reporting of Individuals and Beneficial Ownership of Entities Involved in Specified Transfers of...

Pillsbury Winthrop Shaw Pittman LLP on 9/10/2024

FINCEN’s final rule (RRE Rule), effective December 1, 2025, will require disclosure of the transferor and transferee(s) and the individuals and the beneficial owners of entities involved as transferee in the transfer of...more

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

King & Spalding on 9/10/2024

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

Deciphering FinCEN’s New Anti-Money Laundering Rules for Advisers

Morgan Lewis on 9/9/2024

On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to anti-money laundering/countering the financing of terrorism...more

Investment Advisers Face New AML/CFT Compliance Obligations from FinCEN

Alston & Bird on 9/6/2024

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

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FinCEN › Final Rules

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